Here are some frequently asked questions regarding intellectual property, motion picture and television production, and overseas manufacturing and distribution operations.
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Q: Do you own an extremely promising technology or a valuable patent, copyright or trademark and are concerned about the tax costs of intellectual property (IP) ownership?
A: Consider strategies to park IP in a tax-favored jurisdiction and then commercialize it in a manner that achieves maximum tax efficiency.
Motion Picture and Television Film Production
Q: Are you planning a motion picture or television film or documentary project and are concerned about funding the spiraling costs of production?
A: Consider filming in one of the most favored jurisdictions in the United States and/or worldwide offering film financing tax incentives to maximize cost savings.
Manufacturing and Distribution Overseas
Q: Are you planning to set up/ have in place manufacturing and distribution operations in Europe involving the sale of tangible goods with global affiliates some of which are in high-tax countries?
A: Consider a commissionaire arrangement to reduce the European tax liability of the group while also achieving deferral of U.S. tax.
We believe the U.S. tax strategies referred to herein are consistent with the Internal Revenue Code of 1986 as amended and Congressional purpose and do not relate to Listed Transactions.