The Briefing: Not Terminated - Cher Still Entitled to Her Share of Music Royalties
The Briefing: Not Terminated - Cher Still Entitled to Her Share of Music Royalties (Podcast)
SCOTUS applies the "discovery rule" in timely copyright infringement claim; Cher wins in Marital Settlement Agreement vs Copyright Grant Termination Notices; Student Athletes Win Revenue Share and NIL
Entertainment Law Update Episode 160 – August/September 2023
NFTs and Your Business – Separating Fact From Fiction
NFT Perspectives: A Discussion With Artist and Filmmaker Haik Kocharian
JONES DAY PRESENTS®: Nonfungible Tokens and the Gamification of Markets
Navigating the Once-Obscure German Nonresident Withholding Tax
Nota Bene Episode 111: Charting the New World of Music Royalty Investment with Sid Fohrman
Nonpublication Requests For Patent Applications: Disadvantages
Jones Day Talks Intellectual Property: Blurrier Lines and Narrow Grounds—Implications of the Ninth Circuit’s Blurred Lines Decision
A Focus on Energy: Royalty Trusts
Instapundit: America's IP Laws Need to be "Pruned Back"
On December 19, 2023, the U.S. Treasury Department announced that the Income Tax Treaty between the United States and Chile (the “Treaty”) entered into force. The Treaty was originally signed in February of 2010, and, after...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
Summary: In this 346-page opinion (including multiple concurring opinions and dissents) the Tax Court addresses federal income tax issues arising from 3M Company (3M) and its domestic and foreign subsidiaries’ (Subs)...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 21, 2022 – November 25, 2022...more
In the newly released Proposed Foreign Tax Credit (FTC) Regulations, Treasury provided some measure of relief on cost recovery and royalty withholding, two of the most troublesome aspects of the Final FTC Regulations that...more
New Crypto Products Launch; Singapore Completes DeFi Pilot with Major Banks - In a press release published this week, a major U.S. cross-border payments and money transfer company announced a new service in its existing...more
The Tax Court issued its second opinion in Medtronic following a remand by the US Court of Appeals for the Eighth Circuit (Medtronic, Inc. v. Comm’r, 900 F.3d 610 (8th Cir. 2018)) of its earlier decision. In that...more
Creators, investors, users, and dealers of non-fungible tokens (NFTs) are at the forefront of the intersection of art, music, sports, entertainment, and technology — and they are simultaneously charting a new path when it...more
The sale of a computer program—it seems simple. But, as illustrated by the Treasury Regulations’ computer program characterization rules, the issue of just what a sale of computer program is can become confusing fast....more
Rob Musiala, a Counsel in the Digital Assets and Data Management group and the co-leader of our Blockchain Technologies and Digital Currencies team, breaks down everything you need to know about NFTs, all in 10 minutes or...more
Individuals, estates, and trusts that paid significant amounts of the 3.8% net investment income tax or the 0.9% additional Medicare tax in 2016 or later years should consider filing protective claims for refund of those...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
President Donald Trump signed the U.S. tax reform bill previously entitled the Tax Cuts and Jobs Act into law on December 22, 2017, enacting comprehensive U.S. tax reform with most provisions becoming effective starting on...more
For many years prudent international tax planning for multinational enterprises has included structures designed to minimize global taxes by developing or holding intangible property (IP) in foreign subsidiaries located in...more
In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more
Mean Girls v. The Right of Publicity: Lessons Learned From the Lohan and Gravano Lawsuits - On September 1, 2016, a New York appellate court ended two closely watched right of publicity lawsuits brought by Lindsay...more
Addressing whether certain intercompany technology license agreements were negotiated at arm’s length, the US Tax Court rejected the Internal Revenue Service’s (IRS’s) alleged $1.36 billion tax deficiency and determined that...more
Michael Jackson, Prince and Whitney Houston each revolutionized the music industry and impacted popular music for decades. We all appreciate how Michael Jackson moonwalked across the stage, Prince made it (purple) rain and...more
In March 2014, I reported on the all-out battle that was ensuing in the U.S. Tax Court between the IRS and the Estate of Michael Jackson over the value of the late pop singer’s estate. It began in 2013, when the estate...more
There has been a fair amount of buzz in the days after Prince’s death about his estate plan, whether he has a Will, whether he did or did not do any planning. Time will see this out. Prince’s heirs at law appear at this time...more
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,...more
On September 2, 2015, the U.S. Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued Temporary Regulation § 1.954-2T concluding that third party arrangements cannot be taken into account for...more
In December 2010, the IRS and Treasury proposed regulations that required the allocation of sales-based royalties and vendor allowances exclusively to property that has been sold (or for inventory property, deemed sold under...more