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MANAGING YOUR INTELLECTUAL AND INTANGIBLE PROPERTY:
Best Tax Practices for Domestic and Cross-Border Operations
A Live Two-Hour Audio Seminar from CCH
Thursday, July 9, 2009 - 1 PM Eastern; Noon Central; 11 AM Mountain; 10 AM Pacific
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
Invite Colleagues, Customers, Prospects and Business Referral Sources to Join You!
Learn the Best Tax Strategies for Working with Intangible Assets
Intellectual property (IP) of U.S.-owned companies operating in interstate or cross-border commerce is increasingly becoming the most sophisticated and cutting-edge tax-efficient planning tool in the tax professional’s arsenal. Using the proper strategies and techniques available under present tax laws, there are significant opportunities available through the transfer of the exploitation rights of IP to the proper state and/or foreign jurisdictions.
For many businesses, large and small alike, intangible assets comprise a significant portion of their balance sheet. While these assets provide current and potential future value, a company’s collection of IP is often overlooked. Understanding the tax implications associated with your company’s or your clients’ IP portfolio will allow you or your firm to structure approaches to obtain, transfer, license and dispose of intangible assets to maximize the results. Moreover, since IP rights may extend across state and country borders, knowing the interstate and international aspects of intangible asset transactions will further enhance the value of the portfolio.
For example, with manufacturing moved abroad, for federal tax purposes there are techniques available to maximize U.S. R&D tax credits while removing such non-U.S. exploitation rights legally and permanently from the U.S. tax base. From an interstate perspective, significant legal protection is afforded the U.S. company in moving its IP to a state like Delaware for the availability of uniformity of chancery court laws in protecting such valuable IP from infringement. Additionally, limited state tax arbitrage may be available in such instances but should not drive the transaction.
Join noted tax advisor, author and presenter, William “Bill” Elliott, CPA, ABV, J.D., LL.M. on Thursday, July 9, in a timely and informative two-hour program as he discusses the fundamentals of intangible assets while providing practical strategies to manage the overall IP portfolio. Mr. Elliott will provide thorough coverage of the tax impact on intangibles for both domestic and international transactions. This course is essential for all tax professionals who deal with the intangible assets of their company or of their clients. Time will be provided to ask questions directly to Mr. Elliot via phone or e-mail during the program.
Program Topics
Topics to be addressed include:
- Intellectual Property Transfers and Source of Income
- Transfers of Intangible Assets between “Associated Enterprises” (i.e., Related Parties)
- Transfers of U.S.-Based Intellectual Property to Related Entities
- U.S. Companies with Operations Abroad and the Development, Ownership and Licensing of Trademarks and Trade Names
- Forms of Cross-Border Transfers of Developed Intangibles by U.S. Persons — Coordination with Code Nonrecognition Provisions
- Transfer Pricing Applications and Issues Arising with Cross-Border Transfers or Use of IP Created or Developed in the U.S.
- Tax-Efficient Cross-Border IP Licensing Arrangements in Treaty Jurisdictions
- Cross-Border Cost-Sharing Agreements and Buy-In/Buy-Out of Developed Intangibles
- U.S. Charitable Contributions of Intellectual and Intangible Properties
- The Future of Cross-Border Transfers of IP in the Post-Economic Downturn (2009-2010)
Learning Objectives
- Develop a solid base of knowledge to provide guidance on intellectual and intangible property issues
- Understand interstate and cross-border implications regarding intangible asset transactions
- Recognize the tax and nontax planning opportunities associated with intellectual property
SPECIAL BONUS
Register today for this insightful program on Thursday, July 9 at 1 PM Eastern, Noon Central; 11 AM Mountain; 10 AM Pacific.
About the Speakers:
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WILLIAM P. ELLIOTT, CPA, ABV, CVA, J.D., LL.M.
Partner and Managing Director of International Tax
Cherry, Bekaert & Holland, LLP
Bill Elliott is a Partner and Managing Director of International Tax for Cherry, Bekaert & Holland. He is a Certified Public Accountant and international tax lawyer with more than 25 years of diversified tax planning and compliance experience. As CB&H’s lead International Tax Partner, Bill directs the specialized services and worldwide resources of the Firm to meet the international tax needs of clients firm-wide.
Based in the Firm’s Northern Virginia/Greater Washington, DC office, Bill provides clients with a full range of international tax and accounting services, including international and offshore taxation and planning, wealth preservation and asset protection, domestic taxation, management and business consulting, and litigation and legal advisory services.
Bill specializes in providing strategic planning and advisory services to assist clients across a wide array of industries with inbound and outbound entity transactions, foreign and domestic estate and income tax planning, transfer pricing, intangible and intellectual property valuation, asset protection planning, captive insurance arrangements, expatriate taxation, offshore e-commerce planning, and corporate and pass-through entity taxation and consulting.
Widely recognized for his expertise in tax matters, Bill writes and edits extensively, including contributions to CCH’s TAXES: The Tax Magazine and 1120S Express Answers, the Journal of International Taxation, Tax Notes International, and other leading tax journals and publications. He also is developer of and contributor to self-study CPE programs in the areas of international tax, valuation and S corporations. Bill speaks both domestically and worldwide for state CPA societies and other leading U.S. tax and international tax programs directed to practitioners, as well as programs for individuals and companies needing technical and practical guidance in his areas of expertise.
Prior to joining CB&H, Bill served as the managing international tax partner for Mahoney Cohen and Company in New York City, and previously served as a managing member of DECOSIMO Global, headquartered in Cincinnati and Grand Cayman. He has extensive experience serving clients across several industries, including the manufacturing, distribution, insurance, retail, financial, transportation, not-for-profit, telecommunications, media and franchisee sectors.
Bill graduated with honors from Millsaps College, where he received his Bachelor of Business Administration in Accounting degree. He received his Juris Doctor from the Concord Law School, and graduated summa cum laude with a Master of Law degree (LL.M.) in International Taxation from St. Thomas University School of Law.
Licensed to practice as a CPA in Alabama, Kentucky, Mississippi, New York, Tennessee and Virginia, Bill is a member of the American Institute of Certified Public Accountants (AICPA); the Tennessee, Georgia, and Mississippi Societies of CPAs; the International Tax Planning Association (ITPA); and the International Fiscal Association (IFA). In addition, Bill is a credentialed business valuation and appraisal professional, holding the ABV (Accredited in Business Valuation) and the CVA (Certified Valuation Analyst) designations. |
How the Audio Seminar Works
CCH’s live audio seminars require nothing more than a telephone connection. For the single per-site fee, you can have an unlimited number of listeners at your site participate, get up to speed and in-the-know on important topics, and get special bonus publications included with the seminar. Handout materials are provided in PDF format that you can download and copy for all those who will participate in the seminar at your location.
Practice Development Tip! Invite colleagues, business referral sources, clients and prospects to your office to listen in and participate on this seminar with you. They’ll appreciate your invitation to hear directly about this important topic.
Visit CCHGroup.com/AudioSeminars for more audio seminar topics, dates and times!
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Earn CPE Credit
- Two hours of CPE credit are available for an additional $25 per person wishing to receive a CPE certificate for their participation
- Course Level: Intermediate
- NASBA Field of Study: Taxes
- Prerequisites: A solid background in taxation
- Learn More About CCH’s NASBA Registration
Special Bonus
Firms registering for this audio seminar will receive as a bonus the following publication:
Order CD Recordings of CCH Audio Seminars
If you are unable to attend this upcoming event and would like to order a recording—or if you would like to order recordings of past CCH Audio Seminars, please visit the CCH Audio Seminar Archive Library today.
Pricing:
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Site License: $249 — Registration includes one telephone connection at one location, one master set of handouts (with permission to make additional copies for the participants at your location), an unlimited number of people in one listening room can participate, and one seminar bonus publication per registered site. ($25 CPE fee additional for each person wishing to receive a CPE certificate for their participation.)
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CD Recording: $249 — The CD includes an audio recording of the event and handout materials in PDF format. Includes copy of seminar bonus publication with purchase. Available one week after the live audio seminar event. (Note: CPE credit is not available for the CD version of the presentation.)
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Site License and CD Recording Package: $349 — This specially-priced package provides you with the Site License access to the live audio seminar event AND the CD Recording.
Our Guarantee
If for any reason you are not completely satisfied with this program, we will provide a full refund - no questions asked!
Register Today for Only $249 Per Site and Have an Unlimited Number of Users Participate!
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