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Vancouver Chapter Upcoming Events Taxation of Cross-Border IP Licensing: A Comparison of the United States and Canada The Vancouver chapter of the LICENSING EXECUTIVES SOCIETY invites all LES members and friends to a presentation by James S. Jantos and A. Brent Kerr on taxation of cross-border intellectual property licensing, from both a U.S. and a Canadian perspective. Both speakers bring an unusual combination of qualifications and experience in both tax and technology/IP. DATE: TIME: PLACE: SUBJECT: James S. Jantos will provide a U.S. perspective and A. Brent Kerr will provide a Canadian perspective to various tax issues affecting intellectual property licensing and other transactions involving intellectual property. Such issues could include how intellectual property is taxed in each country from the perspective of the licensor and the licensee, advantages/disadvantages of non-exclusive licenses versus outright dispositions, taxation of international IP transactions (withholding and treaty mitigation), “offshoring”/international IP holding companies (transfer pricing, anti-deferral regimes, rules regarding outbound transfer of intangibles, “cost sharing arrangements”), taxation of cross licensing arrangements (eg. whether cross licensing without an actual exchange of royalties gives rise to constructive royalty payments subject to withholding), etc. Understanding such issues could help you in knowing how best to structure your intellectual property transactions, especially cross-border transactions. SPEAKER: James S. Jantos counsels clients in the areas of international tax and business planning, U.S. federal and state tax compliance, estate planning, and intellectual property. Since 2004, Mr. Jantos has operated his own law firm on Mercer Island, Washington, and has broad experience involving the design and implementation of business and investment strategies for U.S. and foreign entities and individuals. Mr. Jantos received his B.S. degree in Metallurgical Engineering and Materials Science from Carnegie Mellon University in 1990, a J.D. degree from New York University School of Law in 1994, an LL.M. in Taxation and an LL.M. in Intellectual Property Law and Policy, both from the University of Washington School of Law in 2000 and 2006 respectively. Mr. Jantos is a member of the Washington State Bar, is admitted to practice before the U.S. Tax Court, is registered to practice with the U.S. Patent and Trademark Office, and is currently a board member of the LES Seattle Chapter. Brent Kerr practiced in the tax group of one of Canada's national law firms for 27 years, including three years as the managing partner of the firm's Hong Kong office. His practice focuses on tax planning, with an emphasis on international transactions. For several years he has been active in advising on cross-border acquisitions of high-tech companies and international tax issues affecting multi-national corporations. Mr. Kerr received his B.Sc. (Hons.), majoring in mathematics and physics, in 1979. He received his LLB at the same time and was called to the British Columbia bar the following year. In 1993 Mr. Kerr was admitted as a solicitor in England and Wales. He is currently a member of the Salzburg Centre for International Legal Studies, the Canadian Tax Foundation, the Hong Kong – Canada Business Association, the International Society of Trust and Estate Practitioners, the American Mathematical Society, and the International Fiscal Association. COST: Please make cheques payable to the LES Vancouver Chapter, and send payment in advance to Lorraine Duke at the address below. PLEASE RSVP (with payment) no later than Thursday, May 17, 2007 to: Lorraine Duke, Assistant to Hilton W.C. Sue WHO SHOULD ATTEND: THE LICENSING EXECUTIVES SOCIETY: THE LES VANCOUVER CHAPTER: |
