Taxation Issues

Whenever you are dealing with assets, income or financial information, taxation is an important determinant in how you proceed.  There are several tax-specific issues related to intellectual property where IPmetrics can provide an objective point of view.

Transfer Pricing

The success of intra-company IP licensing depends on utilizing the proper structure and charging an "arm's-length" royalty for its use.  IPmetrics will work with your management team and tax professionals to help you determine appropriate royalty rates and the necessary structure to ensure that your program is both beneficial and defensible under Section 482 of the Internal Revenue Code.

Purchase Price Allocation

With certain exceptions, intangible assets associated with a successful purchase may require accounting treatment that can restrict your flexibility.  IPmetrics can assist you in correctly identifying the proper categorization and treatment of intangible assets that may be included in a deal and, through comprehensive and accurate analysis, help you assign the fair market value to these assets.  

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