Migration of Intangible Property: General US Tax Considerations

US multinationals continue to evaluate where their intangible property (IP) should be owned and exploited. This program will discuss certain US tax consequences related to IP ownership and IP migration and areas that US companies should consider in their decision-making process. Specifically, we will cover inbounding and outrounding IP, US and foreign ownership of IP, and planning ideas around each area. 

1. Identify the factors to consider when planning the jurisdiction from which IP economic rights are exploited

2. Describe the general US tax consequences of inbounding IP

3. Evaluate the merits of inbounding IP

4. Assess the merits of retaining foreign IP ownership

5. Describe the general US tax consequences of foreign-to-foreign IP movement