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Intangibles (2nd Edition) published in association with Deloitte

  • Introduction

  • IP: Converging tax, regulatory, and operational factors

    Effective intellectual property (IP) tax planning is increasingly dependent on the convergence of political, regulatory, and operational factors. David Cordova, Michael Bowes, J. Donald Fancher, John A. Hudson, and Sam Chung discuss.

  • The venture valuation model and cost sharing CWI rules

    Marco Fiaccadori, Arin Mitra, and Philippe Penelle provide a practical analysis of the venture valuation model and cost sharing rules.

  • Location-specific advantages: India and China

    The issue of location-specific advantages (LSAs) has received significant attention recently, with India and China formally stating their positions in the UN Transfer Pricing Manual issued October 2012, and in subsequent discussions. Shanto Ghosh, Wei Shu, and Rahul Tomar explore the concept.

  • The evolving procurement model

    Michael Gilson, John Wells, Andrew Feinberg, and Andrew Newman explain why harnessing a company’s procurement function is important in tax planning.

  • Indicia of economic ownership of intangible property

    The question of who owns intangible property has been at the forefront of many transfer pricing controversies. Aydin Hayri and Darcy Alamuddin present a framework for identifying the economic or beneficial owner of intangible property, which from a transfer pricing perspective can be just as important as legal ownership, and illustrates its use in the case study of a hypothetical life sciences company.

  • Transfer pricing of intangibles: Media and entertainment

    The US television production industry, just one of the segments within the media and entertainment space, reported total revenue of $35.6 billion and a profit of $6.1 billion, or 17% of revenue in 2012. Mark Nehoray, Kristine Riisberg, and Anna Soubbotina take an industry focused look at dealing with intangibles.

  • Acquisition premiums and cost sharing analysis

    In the world of mergers and acquisitions, it is fairly common to observe a difference between the actual price paid in acquiring a target company and the preacquisition fair value of the company, the acquisition premium. Keith Reams, Lawrence Shanda, Joe Tobin, and Wen-Fang Liu analyse the concept.

  • International tax issues and cloud computing

    Cloud computing is not only revolutionising the way companies conduct business, it is also raising questions as to how cloud-based businesses should be taxed. Ron Saake and Mandana Malone provide clarity on the issue.

International Correspondents