A very informative article from Kenny Dettman that discusses the possibility of tax-free repatriation of IP to the U.S. Companies should also be aware of the possibility of incurring exit taxes in the distributing country.
As these exit taxes could be based on the fair market value of the IP in the distributing country, at a minimum, a high level understanding of the fair market value of the IP is important to understand the potential implications of repatriating IP to the U.S.
While a 20 percent corporate income tax coupled with various iterations of legislation targeting base erosion payments and high foreign returns may be encouraging enough to deter U.S. multinationals from moving IP offshore, there are key provisions in the Senate’s plan released last week that could make the U.S. look quite advantageous (like Ireland, for example) in terms of favorable IP holding company jurisdictions.
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