Cross-border ventures can unlock exciting destinations for growth and investment, but they also come with some heavy-duty baggage -- think IRS paperwork, withholding headaches, and estate tax landmines. If you're a tax planner gearing up for this global expedition (especially if it's your first trip), this guide is your passport to smoother travels.
Reassessing R&D Structures After the Section 174 Changes
Ted Stotzer
Recent changes to the tax treatment of research and experimental (“R&E”) expenditures may warrant a fresh look at existing intellectual property (“IP”) and research and development (“R&D”) structures. This article examines whether taxpayers should revisit decisions regarding the location of R&D activities, IP ownership, contract R&D arrangements, and related transfer pricing policies in light of the evolving legislative landscape, and how the interaction of Sections 174, 168(k), 59(e), and 163(j) can be used to calibrate a tax-efficient result.
