Now available on CD a BNA webcast originally recorded 13th July 2011 in which leading tax professionals located in the United States, UK, Ireland, and Malta discuss the tax treatment of IP holding companies.
In Tax Treatment of IP Holding Companies, a panel of experts consider from the perspective of four different jurisdictions key issues including the taxation of royalty income, the comparison of the taxation of overseas IP with local IP, incentives for investment in IP, anti-deferral mechanisms and Transfer Pricing and IP.
The portability of intellectual property, for example, means that tax authorities are often concerned that profits can be artificially diverted outside the jurisdiction to reduce a group's tax burden. Yet the UK is introducing an exemption for IP holding companies with a limited UK connection and reviewing the anti-deferral mechanisms currently in place. Other jurisdictions are taking different approaches to the problem and the panel provides valuable insight into these approaches.
The panel also examines, from the perspective of their jurisdictions, the increasingly significant issue of transfer pricing and intellectual property, highlighting particular problems encountered in practice.
The panel of experts includes:
UK: Anne Fairpo, CTA(Fellow), Barrister, 13 Old Square Chambers & Atlas Chambers
Anne Fairpos practice covers UK and international corporate tax planning and disputes, acting for a range of clients from small owner-managed businesses to listed multinationals. Anne is the author of "Taxation of Intellectual Property" and contributes to a number of other publications. She is on the Council of the Chartered Institute of Taxation and chairs the Education Committee of the Institute.
Malta: Michael Ellul, Partner QUBE Services Limited/David Griscti & Associates
With extensive experience at PricewaterhouseCoopers, in 2006 Michael Ellul joined forces with David Griscti and Thomas Jacobsen to establish QUBE Services Limited. The joint organisation QUBE Services Limited/David Griscti & Associates is a market leader in the Investment Services (securities) market and in the area of tax planning and compliance and corporate services in Malta. QUBE Services Limited/David Griscti & Associates is based in the capital city, Valletta, and services an international client base on a multi-jurisdictional basis.
Ireland: Peter Maher, Partner, A&L Goodbody and is Head of the Firm's Tax Department
Peter Maher represents clients in every aspect of tax work, with particular emphasis on inbound investment, cross border financings and structuring, capital market transactions and US multinational tax planning and business restructurings. Peter is regularly listed as a leading adviser in Euromoneys Guide to the Worlds Leading Tax Lawyers, The Legal 500, Whos Who of International Tax Lawyers, Chambers Global and PLC Which Lawyer? 2011 and Who's Who Legal 2010 and 2011. He is a former Co-chair of the Taxes Committee of the International Bar Association and of the Irish Chapter of the International Fiscal Association.
United States: Rocco Femia, Member, Miller & Chevalier
Rocco Femias practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies with the Internal Revenue Service (IRS) and foreign tax authorities involving U.S. international tax rules, transfer pricing, and U.S. tax treaties. Rocco has represented taxpayers before the IRS, the U.S. Department of the Treasury, the Joint Committee on Taxation, and the staffs of the House Ways and Means Committee and the Senate Finance Committee. Rocco has also advised governments on U.S. international tax developments.
Rocco is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy.
Taxation of IP Holding Companies on CD is priced at
