Contingent payment transfers of trademarks: a sale in license clothing

Article Abstract:

Contingent payment trademark transfers are treated as licenses, but should be treated as sales. Contingent payments do not represent a substantial right retained by the original owner, and transfer of all substantial rights characterizes the transaction as a sale rather than a license. Furthermore, Congress has treated the analogous use of contingent payments in patent transfers as sales. The tax law should be changed so that trademarks are handled the same as patents with respect to contingent payment transfers.

Trademark licensing, Trademark licenses

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U.S. income tax treaties in research and planning: a primer

Article Abstract:

Information regarding 48 US income tax treaties is presented for the practical use of tax practitioners. Explanation of the operation of treaties in an international law context is included. The general structure of the treaties is noted as are differences in specific provisions.

Tax Treaties, International Affairs, Laws, regulations and rules, Surveys, Tax research, Directory, Double taxation

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Tax planning for the transfer of franchises, trademarks, and trade names

Article Abstract:

The author discusses the mechanics and legislative history of section 1253 of the Tax Reform Act of 1969, governing the federal tax treatment of a transfer of a franchise, trademark, or trade name.

Analysis, Tax planning, Trademarks, Franchises, Business names

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