Edward Tanenbaum was the moderator of the session,"Tax Planning for "Inbound" Licensing of Intellectual Property," during this meeting sponsored by the American Bar Association. This panel explored the cross border tax issues involved in “licensing” intellectual property into the United States including income characterization issues of whether the transaction is regarded as a sale, license, or service; provided an analysis of the sourcing and withholding tax rules; back to back licensing arrangements and high level transfer pricing issues. The panel covered various optimum licensing structures from the Benelux countries, Switzerland and Ireland and analyzed general treaty considerations as well.
To access a recording of the program please click here.
May 6, 2011
Grand Hyatt Hotel / Washington, DC