Patent Asset Transfers: Tax Implications of Patent Sale, License, Cost Share Arrangement, Contribution
Note: CPE credit is not offered on this program
Recording of a 90-minute premium CLE video webinar with Q&A
This CLE course will guide counsel involved in patent asset transfers, providing a high level overview of tax ownership issues and the tax implications of different types of transfers, including select issues under U.S. tax law such as GILTI and FDII. The panel will address how to ensure the patent is transferred on a tax-advantaged basis.
Outline
- Ownership: legal vs. tax
- Transfer structures and tax implications, including select cross-border impacts and issues under the U.S. tax reform
- Best practices to ensure patent transfer is done on a tax-advantageous basis
Benefits
The panel will review these and other key issues:
- How does ownership differ under the tax rules?
- What impact does the type of transfer have for tax purposes?
- What steps can counsel to transferors and transferees take to ensure that the transfer of patents is on a tax-advantaged basis?
Faculty
Lynn E. Fowler
Partner
Kilpatrick Townsend & Stockton
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and... | Read More
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. He has significant experience in advising clients to qualify for a variety of federal income tax credits. He has also been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions.
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Jeffrey S. Reed
Partner
Kilpatrick Townsend & Stockton
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals... | Read More
Mr. Reed chairs the firm's State and Local Tax Practice. He helps tax directors, business owners, and individuals manage state and local tax risks and exposure, including assessing the strength of corporate tax positions, evaluating whether charges are subject to sales tax, and representing taxpayers in disputes with revenue agencies throughout the U.S. He brings a practical, pragmatic approach to state and local taxation, one that takes into account reserve considerations, legal and administrative guidance, and anticipated revenue agency responses. He is particularly experienced with New York and Massachusetts tax controversies, corporate tax planning, assessing the anticipated state tax consequences of mergers and acquisitions, and analyzing the taxability of electronic commerce and emerging business models. He has resolved disputes with most tax agencies in the United States, and also has broad experience with IRS audits and appeals, and unclaimed property.
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Vanessa Tollis
Partner
Gide Loyrette Nouel
Ms. Tollis specializes in the U.S. tax aspects of cross-border transactions, both inbound and outbound. She advises a... | Read More
Ms. Tollis specializes in the U.S. tax aspects of cross-border transactions, both inbound and outbound. She advises a wide range of U.S. and foreign clients on tax planning for starting or expanding operations abroad or in the U.S. market, including through mergers, acquisitions, reorganizations, and joint ventures, and she advises both participants and sponsors in the global capital markets on securities offerings and tax efficient structured finance, including cross border securitizations.
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