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Self-Study Courses

International Taxation of Intellectual Property (IP) (Currently Unavailable)

2 CPE Credits $31.00/credit hour
5.0 (1 rating)
Per the IRS Education Provider Standards this course must be COMPLETED by 12/31/2024 to receive credits. NOTE: Go to My Professional Profile in your CCH CPELink account settings to ensure your name, and PTIN number; matches your PTIN card

This course will offer select international income tax rules that apply to intellectual/intangible property (IP) transactions. The format of this course will be more high-level and less in-depth because of the timing and number of topics covered. Please read IRC Sections 482, 951, 951A, 954, 250, and 1441 prior to the course.

Publication Date: December 2021

Designed For
Experienced international tax staff through international tax director level interested in or already practicing international taxation.

Topics Covered

  • IP migration and related tax issues background
  • Select income tax background & concepts for IP
  • Select/Overview of IP Tax Planning Considerations
  • Transfer Pricing
  • Application of Section 1441 withholding tax to IP transactions
  • Select International Tax Rules for IP - Recap

Learning Objectives

  • Identify major, select international tax technical provisions that are relevant for IP transactions
  • Recognize select transfer pricing considerations for IP transactions
  • Recognize U.S. source withholding tax considerations for IP transactions
  • Describe IP
  • Describe the US tax system post TCJA
  • Recognize which type of taxation refers to the U.S. tax treatment of U.S. companies that have operations and/or subsidiaries outside the U.S
  • Identify which Section permits the IRS to reallocate gross income, deductions, credits, or allowances among controlled businesses
  • Describe which test involves an assessment of the average value of its assets consisting of assets that produce passive income
  • Identify an agreement between more than two treaty partners

Level
Intermediate

Instructional Method
Self-Study

NASBA Field of Study
Taxes (2 hours)

Program Prerequisites
Basic understanding of international income tax rules.

Advance Preparation
None

Instructor

Adnan Islam

Adnan Islam, Esq., CPA, is a partner with Friedman LLP, co-chair of the International Tax Services group, and a leader of its Blockchain/Digital Asset Transactions group. He has nearly 17 years of public accounting experience as a licensed tax attorney and CPA. Adnan has served an array of industries and clients ranging from startups to publicly traded companies including Avon, MeadWestVaco, Honeywell, Verizon, Agilent, SunGard, Booz Allen, IDT, SunGard, AMEX, OUAI, IBISWorld, Conair, Grayscale, DCG, and various blockchain and crypto (digital asset) companies, exchanges, and private equity and hedge funds. Adnan specializes in cross-border strategies, comprehensive inbound tax services, global information reporting, and structuring for crypto funds, companies, and exchanges.

As an industry thought leader, Adnan has lectured on international tax at TEI events, AICPA seminars and served as an adjunct professor for Golden Gate University Master’s in Tax curriculum. Adnan’s expertise includes advising clients at all stages of business and restructuring, with respect to FDII, GILTI, 245A DRD, subpart F, PFICs, and other issues. Additionally, Adnan empowers his clients’ decision-making and improves their supply chain and operational efficiency, including the use of holding companies, treaty country networks, and affirmative tax planning through comparative rate modeling.

Adnan is a licensed attorney admitted to practice law in New Jersey, DC, and California and a Certified Public Accountant (NY & CA). He holds a Juris Doctor (J.D.) and an M.B.A. from Rutgers University; an LL.M. in Taxation from the New York University School of Law; a blockchain business certificate from MIT; and is currently enrolled in Georgetown Law's Tax LL.M. (International Tax Certificate) program. Adnan has been admitted as a Certified Legal Specialist in Tax Law by the State Bar of California. He also is an (inactive) enrolled agent (through IRS exam).
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