Review the new tax rules, prior approaches to offshore IP planning, and review potential alternative structures.
The Tax Cuts & Jobs Act of 2017 along with actions taken by the European Union have significantly changed the U.S. tax rules applicable to intellectual property. The new rules will require many companies to revisit their IP tax strategies, and possibly cause them to repatriate their offshore IP back to the U.S.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
Overview of Intellectual Property - Trademarks, Copyrights, Patents, Trade Secrets etc.
Tax Cuts and Jobs Act 2017 - Changes to Tax Treatment of IP
- Section 250 - Foreign Derived Intangible Income
- Section 1221 - Capital Assets
- Section 1235 - Patents
- Section 951 - Global Intangible Low Taxed Income
- Section 965 - Accumulated Earnings and Profits
Impact of TCJA of IP Planning
- Outbound Transfers of IP
- Existing Offshore IP Holding Companies - to Keep or to Close?
- Tax Haven Economic Substance Requirement Imposed by the European Union
- Us Developed IP
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on November 1, 2019.
Call 1-866-352-9540 for further credit information.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Charles S. Kolstad
Withers Bergman LLP
- Tax partner Withers Bergman LLP, a leading international private capital law firm, specializing in international tax matters
- Focuses his practice on international tax, corporate, and partnership matters; he assists clients in tax and corporate planning relating to the acquisition, disposition and restructuring of businesses, corporations and partnerships both domestically and internationally
- Frequently advises foreign individuals moving to the U.S. on pre-immigration, income, gift and estate tax planning opportunities; he also focuses his practice on the cannabis industry/cannabusiness, crypto assets and block chain technology, and tax issues related to initial coin offerings (ICOs)
- Has advised over 200 clients with unreported foreign 1nancial accounts, foreign trusts, and other foreign investments, on the 1ling of FBARs and other information returns, and whether participating in the IRS’s various offshore voluntary disclosure programs is appropriate
- Written and lectured on the extensive information reporting requirements for U.S. taxpayers with international business operations
- During his career he’s been at Mitchell Silberberg & Knupp LLP and Venable LLP and was a tax partner at both Coopers & Lybrand and Ernst & Young
- J.D. degree, The University of Notre Dame; M.B.A. degree, Columbia University; B.Sc. degree, Villanova University
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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