A two-day technical update with group live instruction featuring the latest tax planning strategies and opportunities using intellectual property/intangible assets

Benefits of Attending

• Discover tax planning techniques to maximize the value and potential of your intellectual property assets
• Understand the increasing importance of IP-related tax and accounting issues
• Optimize effective tax rates utilizing cost sharing while understanding the latest IRS cost sharing regulations
• Develop an international restructuring and migration of IP offshore
• Examine issues dealing with mergers, acquisitions and dispositions involving IP
• Implement beneficial transfer pricing strategies in relation to IP licensing
• Handle Federal and state tax controversies involving IP assets
• Network with other professional to improve tax strategies and maximize benefits from your intellectual property assets and much more

Educational Course Credit — Up to 15 CPE / CLE Credits Available

Substitutions/Cancellations

Cancellations received more than 72 business hours prior to the meeting will be issued a credit. A $350 fee will apply to cancellations received within 72 business hours of the event. No credit card or cash refunds will be issued at any time. For more information regarding administrative policies, such as complaints and refunds, please contact us at 1-914-328-5656, or e-mail info@citeusa.org. Credits will not be issued for "no shows"

A limited block of rooms at a reduced rate has been set aside for attendees of our conferences. Please contact the hotel and mention that you are attending the conference listed under the Council for International Tax Education (CITE) in order to receive the discounted rate. Sleeping rooms are available on a very limited basis. We cannot guarantee rates or availability. Your sleeping room is not included in your registration fee.Meetings held at conference centers with local hotel recommendations do NOT have rooms blocked

Times/Topics Subject to Change

Day One

7:30 am Registration and Continental Breakfast

8:45 am CITE Introduction

9:00 am Increasing Importance of IP-Related Tax Issues

• How and why IP planning optimizes your effective tax rate
   
• What are IP and intangible assets and how are they different
   
• Integrating IP/IA planning with global tax planning
   
• Remembering the Four Keys to IP/IA planning
  

10:00 am Internal IP Restructuring and Migration of IP Offshore

• Making Effective Use of IP Restructuring
   
• Examples of Effective IP Restructuring
   
• The Seven Types of IP Migration
   
• Migration Consequences and Planning Examples
  

11:00 am Break for Refreshments

11:15 am Financial Accounting Aspects of Software and Intangibles

• When is R&D deductible?
   
• FAS 109 impacts of method differences
   
• APB 23 decisions regarding reinvestment
   
• Fin 48 reserve decisions
   
• FAS- 141 business combination considerations
   
• FAS -142 goodwill and other intangible assets rules

12:30 pm LUNCHEON

1:45 pm IP Licensing and Sec. 482 Transfer Pricing Issues

• Finding the “best method” for establishing US licensing fees in today’s economic environment
   
• Identifying comparable uncontrolled transactions and profit level indicators
   
• Creative use of comparable profits method (CPM)
   
• Testing the range, and the consequence of failure
   
• Comparison to OECD transfer pricing rules
  

3:00 pm Break for Refreshments

3:15 pm Domestic IP Management Companies: State and Local Tax Planning

• Formation and operation of IP management companies
   
• Tax issues in moving the IP into the management company
   
• State and local nexus issues
   
• State challenges of IP management company structures
   
• Planning for the future in a challenging environment
  

4:15 pm Special Tax Planning Considerations for Software

• Federal –Capitalization, start-up expenses, dispositions
   
• State & local –The receipts factor, apportionment planning, canned versus custom, sales tax issues
   
• International- income characterization using Treas. Reg. 1.861-18
   
• Tax rules and issues related to the transfer of software
   
• Planning opportunities
  

5:15 pm Conference Adjourns for the Day

Day Two

7:30 am Continental Breakfast

8:30 am Chair’s Opening Comments

9:00 am Mergers , Acquisitions & Dispositions involving IP Assets

• IP as a core asset in an M&A transaction
   
• Tax compliance in regard to IP in an M&A transaction
   
• Valuation issues
   
• Tax strategies in divesting IP assets
   
• M&A issues for IP in relation to partnerships, LLCs and Hybrids
  

10:15 am Break for Refreshments

10:30 am The Brave New World of Cost Sharing

• The Basics for totally new research
   
• Transfer pricing methods for Basic Cost Sharing
   
• Second Generation Research - The "Buy-In" Concept
   
• New Methods for the "Buy-In"
   
• What to do Now?
  

12:15 pm LUNCHEON

1:45 pm IP Tax Consequences When Structuring Joint Ventures

• Joint venture formation – US tax consequences of transferring IA/IP to a JV entity
   
• IP transfer and valuation issues
   
• Transfer pricing issues for IP in foreign vs. domestic joint ventures
   
• IP license provisions in joint venture agreements
   
• Special issues relating to IP and joint venture structuring: traps for the unwary
  

2:45 pm Break for Refreshments

3:00 pm Handling IP Tax Controversies

• Data sources and reasonableness tests
   
• Valuation issues and approaches
   
• Tax consequences in regard to IP when litigation or problems arise in joint ventures
   
• Advance pricing agreements - pros and cons
   
• A time to settle and a time to litigate
  

4:00 pm How to Manage Corporate Tax & IP Considerations

• Identifying critical and overlapping IP& tax considerations
   
• Tax & IP coordination for IP placed in foreign affiliates
   
• Strategies for legal relationship between parent and foreign IP owning sub
   
• Litigation issues in protecting IP values
   
• Recovering lost profits when IP ownership is separated from sales
   
• Improving communications to avoid problems between tax and IP departments
  

5:00 pm Conference Ends

CITE Conference Registration - Page 1

There are 3 ways to register for a CITE Conference:

1. Complete this form and fax Page 2 to 914-328-5757
2. Call us directly at 914-328-5656
3. Complete the online registration process

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