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The Intellectual Property Holding Company: Tax Use and Abuse from Victoria's Secret to Apple

The Intellectual Property Holding Company: Tax Use and Abuse from Victoria's Secret to Apple

Author: Jeffrey A. Maine; Xuan-Thao Nguyen
Publisher: Cambridge University Press
ISBN: 9781107128262

Published In: December 2017
Format: Hardback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only
Paperback Edition ISBN: 9781107567870

List Price: ¥27,224.34

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Description
Contents

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Many companies that have become household names have avoided billions in taxes by 'parking' their valuable intellectual property assets in holding companies located in tax-favored jurisdictions.

In the United States, for example, many domestic companies have moved their IP to tax-favored states such as Delaware or Nevada, while multinational companies have done the same by setting up foreign subsidiaries in Ireland, Singapore, Switzerland, and the Netherlands.

In this illuminating work, tax scholar Jeffrey A. Maine teams up with IP expert Xuan-Thao Nguyen to explain how the use of these IP holding companies has become economically unjustified and socially unacceptable, and how numerous calls for change have been made.

This book should be read by anyone interested in how corporations - including Gore-Tex, Victoria's Secret, Sherwin-Williams, Toys-R-Us, Apple, Microsoft, and Uber - have avoided tax liability with IP holding companies and how different constituencies are working to stop them.

1. Introduction

2. The Delaware gift to corporations

3. The domestic IP holding company's structure and phantom

4. The scrutiny from the States

5. Domestic tax haven

6. Key incentives to created foreign intellectual property holding companies

7. International structures used by Apple and other multinational companies

8. Government barriers to intellectual property income shifting and their (in)effectiveness

9. Foreign tax havens: exploring solutions to intellectual property income shifting offshore

10. Final thoughts on IP holding companies and corporate social responsibility.