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  • videocam On-Demand
  • signal_cellular_alt Intermediate
  • card_travel Corporate Tax
  • schedule 110 minutes

Taxation of Intellectual Property: Classifying Intangibles, Determining Domicile, Holding Structures, Amortization

$247.00

This course is $0 with these passes:

CPE
ALL
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Description

Intellectual property is a broad description covering patents, copyrights, processes, trademarks, software, and a number of other types of intangible property. Different property types are subject to different tax guidelines in the U.S. Amortization rules vary based on the property type. Self-created property could be subject to Section 167 amortization, trade names and trademarks to Section 197, while Section 174 applies to R&E expenses.

Not only are the guidelines for expensing these assets voluminous and complex, where the IP is created and used affects its taxation. Introduced as part of the Tax Act of 2017, the GILTI regime is meant to equalize taxes paid in the U.S. with those paid overseas on these easily transferable assets. The revised provisions of GILTI, FDII, and the preexisting Subpart F muddle the decisions of where to locate these mobile assets and the choice of holding entity. Tax practitioners working with domestic and multinational entities that own, purchase, transfer, or create these assets need to understand and plan for the acquisition, transfer, and expensing of these valuable assets.

Listen as our panel of IP attorneys explains key features of these intangible assets so that tax advisers and businesses can maximize the tax benefits of owning these worthwhile resources.

Presented By

Stuart Anolik
Partner
FisherBroyles, LLP

Mr. Anolik has handled client matters involving international investment and finance, intellectual property migration, transfer pricing, infrastructure project finance, mergers and acquisitions, and international taxation. These clients range from start-ups to Fortune 500 companies, on various international securities and transactional matters, including multi-jurisdictional acquisitions and dispositions of business; cross-border joint ventures; and securities transactions and financings for the U.S., European, Asian, and Latin American companies. In addition, he provides consulting services to high net worth individuals in regard to estate planning, wealth preservation, and asset protection planning.

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Kevin Jablonski
Partner
FisherBroyles, LLP

Mr. Jablonski is a registered patent attorney with a focus on patent portfolio development and patent prosecution. He works with a number of clients across myriad technologies with a lean toward electrical engineering and computer science.Mr. Jablonski’s practice involves additional aspects of intellectual property law including IP licensing, copyrights, and trademarks. He is registered to practice before the United States Patent and Trademark Office and admitted to practice law in Washington State. Mr. Jablonski has experience in technology areas such as semiconductor design, analog and digital circuits, LTE Wireless, computer networking, digital communication systems, , computer-related business methods, interactive software solutions, aircraft manufacturing systems, IoT systems, and computer architecture solutions.

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Thursday, April 20, 2023

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

  1. Definition of intellectual property
    1. Codified intangibles
        1. Patents
        2. Trademarks
        3. Copyrights
        4. Trade secrets
    2. Other intangibles
        1. Good will
        2. ii. Marketing
        3. iii. Workforce in place
        4. iv. Publicity rights
  2. IP creation
    1. U.S. vs. non-U.S.
    2. Cost sharing
    3. Cross border tax implications
  3. Mobile income
    1. Choice of offshore domicile, patent box regimes
  4. U.S. international tax issues
    1. GILTI
    2. FDII
    3. Subpart F
    4. Super royalty provisions under Section 367(D)
  5. Transfer pricing considerations
    1. License or sale of IP
    2. Services

The panel will review these and other critical issues:

  • Tax treatment of intellectual property by type of property
  • Tax considerations for self-created property
  • Locating the intangible asset: U.S. or abroad
  • GILTI and FDII taxation of intellectual property
  • Choice of offshore domicile

Learning Objectives

After completing this course, you will be able to:

  • Ascertain key planning considerations when acquiring or disposing of IP
  • Determine how IP is taxed under GILTI guidelines
  • Decide which offshore entity is most appropriate in specific scenarios
  • Identify applicable amoritzation methods by IP classifications
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

BARBRI is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .