Intellectual property (“IP”) is typically monetized either by sale or (royalty generating) license agreements. The Code often allows sales to be taxed at preferential capital gains rates while simple royalties are ordinary...more
Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with creating assets having useful...more
Intellectual property (“IP”) is hugely important to businesses. Given that importance, IP owners must occasionally litigate against the unauthorized use of their technology. The costs of such litigation and appurtenant...more
2/21/2024
/ Intellectual Property Litigation ,
Intellectual Property Protection ,
Internal Revenue Code (IRC) ,
IRS ,
License Agreements ,
Litigation Fees & Costs ,
Patents ,
Settlement Agreements ,
Share Purchase Agreements ,
Tax Deductions ,
Tax Liability ,
Tax Planning
Cryptocurrency holders often want to put their assets into an entity for a host of reasons, such as asset protection, arranging negotiated management rights and exit planning. This post discusses basic federal income tax...more
In January 2021, the U.S. Department of Treasury and the Internal Revenue Service released final regulations (the Final Regulations) under Section 1061 of the Internal Revenue Code of 1986, as amended (the Code). Code...more
On January 31, 2020, the IRS issued a news release that warns taxpayers that it has created 12 new examination teams to audit abusive micro-captive insurance transactions.
“Micro-captive” refers to a small insurance...more