Lexis Nexis Taxation of Intellectual Property and Technology
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Product description
This newly revised edition of Taxation of Intellectual Property and Technology fully integrates the latest legislative, administrative, and judicial changes in the tax law as well as the patent, trademark, and copyright and trade secret laws, and additionally covers Internet and international taxation. It is a comprehensive guide to the federal tax consequences of the development, purchase, sale and licensing of intellectual properties, including inventions (whether or not patentable), trade secrets, trademarks, trade names, copyrights and computer software. Taxation of Intellectual Property and Technology not only explains and analyzes the complex issues involved in this growing area of law, it recognizes and addresses the need to minimize the tax impact of these transactions. Coverage now includes:
• Analysis of the America Invents Act and its effect on patentable inventions
• Intangibles costs under IRC § 263(a) and INDOPCO
• Property versus Services and Employee to Employer Transfer
• Calculation of the Qualified Research Expense Credit
Tax law and intellectual property are highly transitory and complex, and often interact in uncertain ways, especially in the face of rapid and continual technological development and the growth of e-commerce. Taxation of Intellectual Property and Technology is an indispensable resource for intellectual property and tax professionals and for any attorney or accountant whose practice touches or concerns these fields.
Also available in the LexisNexis Tax Center.
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Featured Authors
William H. Byrnes
William H. Byrnes (Principal Author and Original Author of the Fourth Edition) is an Executive Professor of Texas A&M University School of Law, is a prolific author of ten LexisNexis international tax and federal tax treatises, three Tax Facts books of National Underwriter, and over 1,100 tax articles. In 1994, he pioneered an online international tax graduate program and in 1998 the first online LL.M. offered by an ABA law school. He held a senior position of international tax at Coopers & Lybrand (South Africa) specializing in international taxation and transfer pricing. Professor Byrnes undertook a three-year transfer pricing fellowship at the IBFD in conjunction with an LL.M. at the University of Amsterdam. His Lexis treatises include Taxation of Intellectual Property and Technology; Practical Guide to U.S. Transfer Pricing; Foreign Tax and Trade Briefs; Guide to FATCA Compliance; Money Laundering, Asset Forfeiture and Recovery, and Compliance; Tax Havens of the World; Federal Taxation of Oil & Gas Transactions; International Business Planning: Law and Taxation; Texas Estate Planning; and International Withholding Tax Guide. He may be contacted at williambyrnes@gmail.com.
Table of contents
VOLUME 1
PART I INTRODUCTION
Chapter 1 Overview of Intellectual Properties
Chapter 2 Outline of Major Code Sections Applicable to Intellectual Properties
PART II TAX PLANNING FOR THE CREATION, DEVELOPMENT, AND PURCHASE OF INTELLECTUAL PROPERTY
Chapter 3 Development and Purchase of Technological Intellectual Properties Including Patents and Trade Secrets
Chapter 4 Development and Purchase of Trademarks and Trade Names
Chapter 5 Creation and Purchase of Copyrights
PART III TAX PLANNING FOR THE SALE AND LICENSING OF INTELLECTUAL PROPERTY
Chapter 6 Sale and Licensing of Technological Intellectual Properties Including Patents and Trade Secrets
Chapter 7 Sale and Licensing of Trademarks and Trade Names
Chapter 8 Sale and Licensing of Copyrights
VOLUME 2
PART IV SPECIALIZED TAX PLANNING APPLICATIONS
Chapter 9 Research and Development Tax Credit
Chapter 9A State Research and Development Tax Credit
Chapter 10 Computer Software
Chapter 10A The Imposition of Sales Tax on Computer Software
Chapter 11 Taxation of Electronic Commerce
Chapter 12 International Transactions
Chapter 13 Global Positioning of Intellectual Property
Chapter 14 Transfer Pricing for Intangibles
Chapter 15 Permanent Establishment for E-commerce Transactions
Chapter 14 Transfer Pricing for Intangibles
Chapter 15 Permanent Establishment for E-commerce Transactions
Chapter 16 The Customs Valuation of Intangibles or Services in International Trade
Appendix A Primary Internal Revenue Code and Regulations Sections
Appendix B Primary Revenue Rulings and Revenue Procedures
Appendix C Primary Internal Revenue Service Letter Rulings and Notices
Table of Cases
Table of Statutes
Index
