State legislatures and courts have forced the once-lucrative intangible holding company (IHC) and passive investment company (PIC) tax strategies out of existence. Many states now will declare income tax nexus on companies leasing intangible assets like trademarks from related entities.
However, new possibilities arose in the wake of those outlawed tax-planning strategies. For example, corporate parents might consider charging related entities service fees rather than royalties, creating embedded royalty companies, or selling intangible assets under Sect. 197.
Staying abreast of the new opportunities being crafted to replace IHCs and PICs is imperative for tax professionals and counsel in order to take advantage of their substantial savings potential.
Listen and participate from your telephone as our panel of veteran tax advisors updates you on evolving tax planning strategies and practices you can use now.
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