Challenges of Transferring IP Offshore -
What constitutes intellectual property (“IP”) has long been a contested issue in tax practice, but generally includes intangible assets as wide-ranging as patents, copyrights, secret processes and formulas, goodwill, trademarks, and trade brands. IP is extremely valuable as a tax asset because it often takes years to develop, which allows the taxpayer to incur losses and expenses, which can offset a taxpayer’s U.S. source income.
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