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

Benefits of Attending

• Devise tax planning techniques to maximize the value and potential of your intellectual property assets
• Understand the increasing importance of IP-related tax issues
• Benefit from internal IP restructuring & migration of IP offshore
• Utilize beneficial transfer pricing strategies in relation to IP licensing
• Structure tax planning strategies for software, licensing IP to JVs and M&A tax planning in regard to IP assets
• Understand the latest IRS cost - sharing regulations and ways to deal with challenges to contract manufacturing
• Learn how to deal effectively with IP tax controversies
• Determine the role of valuation techniques in regard to IP assets
• Network with other professionals to improve tax strategies and maximize benefits from your intellectual property assets

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

Monday, October 25th

8:00 am Registration and Continental Breakfast

8:45 am Introduction and Co-Chairs Welcome

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

9:45 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 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

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 controversy environment
• Recognizing potential comparable uncontrolled transactions and comparability considerations
• Applying profit-based approaches to IP licensing
• Testing the range and the consequence of failure
• Comparison to OECD and other tax jurisdiction guidelines

3:00 pm Break for Refreshments

3:15 pm Use of 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
• International planning issues
• Planning for the future in a challenging environment       

4:15 pm Special Tax Planning Considerations for Software Electronic Commerce & Internet Based Activities

• Federal –Capitalization, start-up expenses, dispositions
• 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

Tuesday, October 26th

8:00 am Continental Breakfast

8:45 am Mergers , Acquisitions & Dispositions involving IP Assets

• Section 197--what's covered and what's excluded
• Uncertain scope of the anti-churning rules
• Measuring section 1245 recapture on disposition of acquired IP
• Recognizing loss on disposition of acquired IP

9:45 am Break for Refreshments

10:00 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?

11:30 am Handling IP Tax Controversies

• IRS re-organizations to address 482 IP issues 
• Settlement approaches with IRS auditors 
• Advance pricing agreements - pros and cons
• Challenging IRS regulations after the Mayo Foundation case 
• A time to settle and a time to litigate

12:30 pm LUNCHEON

1:30 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

2:30 pm Break for Refreshments

2:45 pm 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

3:45 pm Valuation of Intellectual Property & Intangible Assets

• Valuation principles and techniques
• Market & cost approaches – comparable licensing/royalty rates
• Income forecast approach – selecting the proper discount rate
• Valuation in relation to migrating or transferring IP abroad
• Tax and accounting issues in relation to IP valuation-
• Valuation of IP in relation to M&A and business combinations

4:45 pm Summary & Q&A

5:00 pm Conference Ends

Bloomberg BNA | CITE Conference Registration - Page 1

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