Tax 101: Deemed Annual Royalty on Outbound Transfers of I.P. to Foreign Corporations

Volume 4 No 9    |    Read Article

By Stanley C. Ruchelman and Elizabeth V. Zanet

U.S. tax law contains provisions that attempt to discourage the outbound migration of intangible assets including specific rules that target transfers affected through corporate inversions. Elizabeth V. Zanet and Stanley C. Ruchelman discuss the history and current standing of those provisions, while pointing out an alternative that is currently available to limit ongoing tax liability in the context of a start-up operation.    See more →