We found a match
Your institution may have access to this item. Find your institution then sign in to continue.
- Title
Subpart F: Gain from the Sale of Intangible Property.
- Authors
Yoder, Lowell D.
- Abstract
The author advocates that the gain earned from the sale of intangible property, such as trademarks, copyrights, and patents, is accounted as foreign personal holding company income (FPHCI) rather than royalties earned by a controlled foreign corporation (CFC). He exemplifies with LuxCo, a producer, importer and marketer of beverage alcohol products, which possess certain intangible property and licenses to operate CFCs.
- Subjects
CONTROLLED foreign corporations -- Law &; legislation; INTANGIBLE property; ROYALTIES (Copyright); COPYRIGHT; ROYALTIES (Patents); ROYALTIES (Trademarks); LUXCO Inc.; ALCOHOL; ECONOMICS; MARKETING
- Publication
International Tax Journal, 2013, Vol 39, Issue 4, p3
- ISSN
0097-7314
- Publication type
Article