More evidence
Black 17, Associate Dean for Strategy and Innovation, Professor of Law, Texas Tech University School of Law; LL.M. Taxation, University of Washington School of Law (2000); J.D., J. Reuben Clark School of Law, Brigham Young University (1994); B.S., Brigham Young University (1988). (Stephen T., Fall 2017, ARTICLE: The Copyright Box Model, 41 Seattle U. L. Rev. 179, 179. Lexis accessed online via KU libraries)
Intellectual property law is territorial in nature. That is why intellectual property assets have always been favorites among international tax planners. Rapid appreciation, even faster transfer times, and a somewhat vague standard for appraisal and valuation make for an interesting field of play. Transfer the assets to a low tax jurisdiction before the appreciation begins, and you find yourself with a large income stream that is taxed at a low rate. Miss the beat, and you have a large tax hit.