Question 1:
"Licensing of Intangible Property" Please respond to the following:
- The licensing of intangible property is a commonplace occurrence in foreign countries. Choose any type of intangible property and propose a strategy to minimize or eliminate the tax impact of licensing.
- You have been hired by a U.S. corporation that wants to invest in a foreign corporation through the transfer of intangible property. Make a recommendation to your client as to how to transfer the intangible property and thus mitigate or eliminate the tax impact of the transfer.
Question 2:
"Foreign Investments" Please respond to the following:
- You have been hired by a U.S. corporation that wants to expand its business to a foreign country. Evaluate the approaches to expanding into a foreign country and create an argument for the approach you would recommend.
- Your client has asked you to assess the methods of capitalizing a foreign corporation that produces the most advantageous tax position. Propose a method that produces the least amount of tax for your client.