My colleagues and I co-authored a chapter in Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties, which is a book that analyzes taxation of intellectual property in various countries and under EU law. The chapter we authored provides an in-depth analysis of the U.S. tax regime and tax treaty practices around intellectual property.
Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties, comprising the proceedings and working documents of an annual seminar held in Milan in November 2017, is a detailed and comprehensive study on the taxation of intellectual property (IP). It begins with a comparative analysis of the domestic private law aspects of IP and the domestic tax regimes applicable to profits deriving from the utilization of IP. Individual country surveys provide an in-depth analysis of the domestic tax regimes and actual tax treaty application and practices by various states, including Australia, Austria, Brazil, Canada, China (People’s Rep.), France, Germany, Italy, the Netherlands, Spain, Switzerland, the United Kingdom and the United States.