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Licensing of Intangible Property

Licensing of Intangible Property
  • The licensing of intangible property is a commonplace occurrence in foreign countries. Choose any type of intangible property and propose a strategy to minimize or eliminate the tax impact of licensing.
  • You have been hired by a U.S. corporation that wants to invest in a foreign corporation through the transfer of intangible property. Make a recommendation to your client as to how to transfer the intangible property and thus mitigate or eliminate the tax impact of the transfer.

Please keep the bullet point and solution together and make the solution at least a paragraph long.




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One benefit of a US company holding intangible property through a non US affiliate is the potential to lower the rate of taxation on the income earned through the intangible property. This however depends on the jurisdiction of the non US affiliate. For lower rates of taxation, this affiliate must be in a low-tax jurisdiction. A good example of an intangible property that can be used to eliminate tax is a patent. A US company holding…


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