That’s why IP tax havens exist
Hadjilogiou* Barrett**, and Tevel*** 13, *attorney at Baker & McKenzie law firm in Miami, who counsels with respect to international tax planning. His practice includes worldwide tax minimization, state and local tax planning, and partnership taxation. He is an adjunct professor at the University of Miami School of Law Tax LL.M. program. **partner at Baker & McKenzie, LLP, in Miami, where he serves as the chair of the tax department. He is a co-chair of The Florida Bar Tax Section, Long Range Planning Committee, and practices in the area of U.S. federal income tax, focusing on outbound and inbound international tax planning. *** member of Baker & McKenzie's tax practice group in Miami. His practice mainly focuses on international tax planning. (Steven*, James**, Sean***, January, 2013, ARTICLE: THE BENEFITS OF TAX PLANNING AS PART OF THE ACQUISITION OF AN INTERNATIONAL BUSINESS, 87 Fla. Bar J. 40, Lexis accessed online via KU libraries)
P22 Proper planning of the ownership and use of intellectual property is one of the most significant planning techniques to reduce a company's global effective tax rate and is utilized by most Fortune 1000 companies. Intellectual property, which includes a company's trademarks, copyrights, know-how, and trade secrets, generally constitutes the most valuable asset of any business. The acquisition of a multinational enterprise provides the opportunity for the acquirer to hold and manage its intellectual property that is geographically limited in scope to the U.S. in a U.S. entity and its foreign intellectual property outside of the U.S. through a foreign subsidiary. Future IP that is developed for use outside of the U.S. is developed by the foreign subsidiary and future U.S. IP is developed by the U.S. entity. As such, profits generated pursuant to the exploitation of the foreign IP is not taxed in the U.S.
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