TAX
THE CIRCULAR 230 DESKBOOK • RELATED PENALITES • REPORTABLE TRANSACTIONS • WORKING FORMS Jonathan G. Blattmachr (Retired, Milbank, Tweed, Hadley & McCloy LLP) and Mitchell M. Gans (Hofstra University)
TAXATION OF INTELLECTUAL PROPERTY LAW AND PRACTICE
Jeffrey A. Maine (University of Maine School of Law) and Xuan-Thao N. Nguyen (University of Washington School of Law)
This resource helps IP practitioners, tax professionals, and owners learn about and leverage important deductions and tax planning strategies pertaining to IP transactions and IP asset ownership. The distinguished IP professors who authored this book explore critical tax considerations and preparation pointers appropriate for accommodating the IRS and state tax agencies. Readers will gain exposure to IP taxation fundamentals relevant to individuals, corporations, partnerships, and non-profits. The book includes in-depth coverage of the various deductions applicable to patent royalties, researchers, and infringement-related legal fees, as well as a state-by-state treatment of the IP holding company model. In addition, the authors discuss administrative rulings addressing the tax treatment of resource planning software, wage allocation in association with the research tax credit, and technology licenses. Respond to IP taxation developments quickly with PLI’s Upkeep Service.
This Deskbook , written by professors and practitioners with significant experience, offers important practice tips and compliance guidelines for anyone who practices before the IRS. Readers can access sample disclaimers, memoranda, and checklists when encountering key matter milestones, along with important IRS forms necessary for effective practice. In addition, readers will learn important defenses and safe harbors for avoiding IRS penalties and compliance missteps. Stay ahead of practice developments with PLI’s Upkeep Service. 1 looseleaf volume, 1,098 pages, $696, Item #9134, ISBN 978-1-4024-0754-3, Updated annually or as needed
1 looseleaf volume, 1,296 pages, $680, Item #325516, ISBN 978-1-4024-3908-7, Updated annually or as needed
TRANSFER PRICING ANSWER BOOK
Edited by David B. Blair (Eversheds Sutherland (US) LLP)
Amortization of R&D Costs: Practical and Policy Implications For nearly seven decades, taxpayers were permitted to immediately write off (i.e., deduct) 100% of research and development (R&D) expenditures when paid or incurred. Not now. The Tax Cuts and Jobs Act of 2017 eliminated, prospectively, 100% expensing for R&D. For tax years beginning in 2022, “specified research or experimental expenditures” (including software development costs) must be amortized ratably over five years (fifteen years for foreign research) ...
Created by a practitioner with more than two decades of experience, this title walks executives at MNEs and their counsel through tactics for mitigating tax liability and costs around intercompany transactions. In a reader-friendly question-and-answer format, corporate counsel, tax practitioners, and MNE leaders will find thorough and non-technical discussion of court-tested strategies. This approach helps distill often complex transfer pricing topics into an easy-to-follow format for any reader, regardless of their experience or familiarity with taxation or transfer pricing issues. Track transfer pricing legal developments with PLI’s Upkeep Service.
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1 softbound volume or digital, 720 pages, $290, Item #422968, ISBN 978-1-4024-4288-9, Published annually or as needed
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