Patent Asset Transfers: Tax Implications of Patent Sale, License, Cost Share Arrangement, Contribution
Note: CPE credit is not offered on this program
Recording of a 90-minute premium CLE webinar with Q&A
This CLE webinar will guide counsel involved in patent asset transfers, providing a high level overview of tax ownership issues and the tax implications of different types of transfers, including select issues under the new US tax reform such as GILTI and FDII. The panel will address how to ensure the patent is transferred on a tax-advantaged basis.
Outline
- Ownership: Legal vs. tax
- Transfer structures and tax implications, including select cross-border impacts and issues under the new US tax reform
- Best practices to ensure patent transfer is done tax advantageous basis
Benefits
The panel will review these and other key issues:
- How does ownership differ under the tax rules?
- What impact does the type of transfer have for tax purposes?
- What steps can counsel to both transferors and transferees take to ensure that the transfer of patents is on a tax-advantaged basis?
Faculty

Lynn E. Fowler
Partner
Kilpatrick Townsend & Stockton
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and... | Read More
Mr. Fowler focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. He has significant experience in advising clients to qualify for a variety of federal income tax credits. He has also been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions.
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Don Reiser
Managing Director
CBIZ
Mr. Reiser has more than 30 years of experience providing international tax consulting services to public and... | Read More
Mr. Reiser has more than 30 years of experience providing international tax consulting services to public and privately-held U.S. and foreign-based corporations as well as foreign individuals and businesses investing in the U.S. He addresses a broad range of domestic and foreign tax matters. His extensive experience includes advising U.S. and foreign clients on the tax implications of cross-border mergers and acquisitions, divestitures, international joint ventures, reorganizations, cross-border financings, and post-deal integration transactions. He has an in-depth background designing and implementing tax efficient global business structures involving intellectual property ownership and exploitation, contract and toll manufacturing arrangements, limited risk sales and distribution structures, holding and finance companies, and more.
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Vanessa Tollis
Partner
Gide Loyrette Nouel
Ms. Tollis specializes in the U.S. tax aspects of cross-border transactions, both inbound and outbound. She advises a... | Read More
Ms. Tollis specializes in the U.S. tax aspects of cross-border transactions, both inbound and outbound. She advises a wide range of U.S. and foreign clients on tax planning for starting or expanding operations abroad or in the U.S. market, including through mergers, acquisitions, reorganizations, and joint ventures, and she advises both participants and sponsors in the global capital markets on securities offerings and tax efficient structured finance, including cross border securitizations.
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