12th Annual NYU/KPMG lectures address the taxation of intangibles in a global economy
The taxation of intangibles in a global economy was the focus of the 12th Annual NYU/KPMG Lectures on Current Issues in Taxation, held at NYU Law on April 10.
The day started off with Alan Dixler giving an overview of the U.S. taxation of intangibles focusing on their development, economic/legal ownership and exploitation in a multinational corporate environment. Professor John P. Steines Jr. (LL.M. ’78) followed with a treatment of outbound transfers of intangibles from the United States.
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In the second half of the morning, KPMG's Thomas Zollo discussed common supply chain business models used by U.S. multinationals in structuring the acquisition, development and exploitation of intangibles. KPMG's Stephen Blough and Charles Cope examined transfer pricing and valuation issues, including focus on cost sharing arrangements.
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Introduced by Joshua Blank (LL.M. '07), associate professor of the practice of tax law, Manal Corwin, deputy assistant secretary of international tax affairs at the U.S. Department of the Treasury's Office of Tax Policy, delivered the event's keynote address on “Taxation of Intangibles in a Global Economy – A Moving Target.” The keynote address was followed by a debate, moderated by Professor Willard Taylor. Debate participants included the U.S. Department of the Treasury's Manal Corwin, Wayne Perry Professor of Taxation Daniel Shaviro, Baker & McKenzie's Marc Levey, and KPMG's Thomas Zollo. After the debate, KPMG's Patric Jackman discussed post acquisition planning for intangibles.
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KPMG's Sean Foley moderated a corporate tax panel on practical insights concerning intangibles from representatives of corporate America. Participants included Louise Weingrod, vice president and tax counsel at Johnson & Johnson, and Bruce Lassman, vice president of international tax at IBM Corporation. To conclude the day, Anne P. Shelburne from the office of the associate chief counsel international at the IRS and KPMG's Brett Weaver and Greg George spoke about emerging issues in delivery of digital media, including cloud computing.
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Posted April 18, 2012