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As of late, banks around the world have also started to collaterise intangible property assets.
For example, if a domestic corporation licenses intangible property to a foreign subsidiary, and then the foreign subsidiary uses the intangible property in selling its products to unrelated foreign customers, the royalty income earned by the domestic corporation should qualify as FDDEI.
The themes are the boundaries of tangible and intangible property, and the doctrinal issues regarding the acquisition, content, and destruction of property rights.
The notice addresses the sourcing of receipts from the sale of services and the rental, lease, or license of intangible property, as well as when certain receipts are to be excluded from sales altogether.
* Issues in connection with the sale of intangible property, including interest and dividends; and
Additionally, debt under the credit facility is guaranteed by some of the company's US subsidiaries and secured by a first priority security interest in certain tangible and intangible property and assets of some of its subsidiaries.
Christy's transfer pricing knowledge covers a wide range of technical areas including: controversy management, alternative dispute resolution, tax and supply chain restructuring, financial modeling, intangible asset valuation, M&A due diligence, cost sharing arrangements, intangible property licensing and migration, tangibles and services benchmarking, and global planning and documentation studies.
On appeal, the assessor also argued that the Uniform Standards of Professional Appraisal Practice (USPAP) "requires that all interests, obligations, and rights inherent in ownership of immovable property be reflected in establishing its fair market value." The assessor cited Advisory Opinion 14 to USPAP, which discusses that LIHTC may create intangible property rights in a property.
In recent years, the legislative, judicial, and executive branches have all attempted to clarify the meaning of "intangible property" under Sec.
The nonbinding letter of intent has been signed for the acquisition of business assets including R and D, USA, LLC's means of production of soy meal and soy oil products and non-GMO products, certified organic products, refined oils, agricultural oils, and other related specialty fertilizer crop products, including all intellectual and intangible property.
Governments establish patent box regimes to encourage businesses to develop, own and exploit intangible property in their jurisdictions.
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