US: Business restructuring and the role of intellectual property

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

US: Business restructuring and the role of intellectual property

January 03 2012

In today’s increasingly global business climate, intellectual property (IP) has become a major driver in corporate profits, both from an innovation point of view as well as from a global branding perspective. David Cordova, Arin Mitra, Andrew Newman, Keith Reams, Larry Shanda, and Alan Shapiro of Deloitte explain how taxpayers can navigate new obstacles in IP planning

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

Intellectual Property (December 2011)
more across site & shared bottom lb ros

More from across our site

Direct Tax
TP document - compliance.jpg
How integrated FP&A data powers pillar two compliance
Pillar two compliance is creating unprecedented data demands for multinational tax departments, making closer collaboration with FP&A teams essential for accurate reporting and audit readiness
Chris Porter, July 23 2026
Direct Tax
New York, USA - 29 September 2020: Australian Government Taxation Office ato.gov.au company website with logo close up, Illustrative Editorial
KordaMentha launches tax disputes practice with ATO, PwC Australia hires
Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
Sam Sholli, July 22 2026
Podcasts
KPMG australia podcast article header
Podcast: What the KPMG Australia scandal means for the big four
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
Tom Baker, July 22 2026
Direct Tax
pound notes
MHA records 12% revenue rise a year on from London IPO
The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe
Sam Sholli, July 21 2026
Direct Tax
Michael Ebeid and John Sams, KPMG
KPMG Australia’s new CEO vows to improve culture following scandal
Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said
Tom Baker, July 21 2026
Transfer Pricing
Intellectual property Africa
Pay attention to tax when taking IP across borders in Africa
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
The tax team at Bowmans, July 21 2026
Direct Tax
Global digital
Beyond the headlines: Lessons from pillar two’s first and farcical filing deadline
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
Tom Baker, July 20 2026
Direct Tax
Compliance frustration onerous pillar two
A taxing week: Pillar two revenue shortfall a gut-punch for MNEs
After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs
Tom Baker, July 17 2026
Direct Tax
EY
The EY US dispute: why secondment structures need fresh Indian review
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
Aditi Goyal, July 16 2026
Direct Tax
OECD
Pillar two revenues lower than anticipated, OECD admits
Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’
Sam Sholli, July 15 2026
Gift this article