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Please condition any assumptions that you are feeling should be made. This analysis is based on the assumption that the distributions do not surpass the adjusted basis of the stock. This evaluation is dependant on the assumption that the distributions occur from U.S. This analysis is dependant on the assumption that the shareholders aren’t considered “related parties” as defined by the inner Revenue Code and are not 10% shareholders.
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Your customer X Co, a non-US Corporation, is within the pharmaceutical industry and a drug has been developed by them that they think will cure Nile Fever. In this regard these are entering into a licensing agreement with Y Inc, a US Corporation. The conditions of the licensing contract are below. Will the following payments to be made by Y Inc to X Co be at the mercy of US withholding tax (“WHT”)? Royalty income is sourced to the place where the intangible property is utilized (Code Secs.
Thus, if intangible property is utilized in the United States, it is U.S. If the intangible property is utilized outside the United States, it is international source income. If the house can be used both in america and beyond your United States, a reasonable allocation must be made then. Under the principles of Rev. Rul.
This is true even if the computation of the payment is dependant on a share of the receipts from the sale. The deciding factor was whether the intellectual property is moved for its remaining life (sale) or for a period significantly less than its remaining life (permit). Even if a deal is treated as a sale, when the purchase consists of an intangible, Section 865(d)(1)(B) applies the royalty source rule to obligations that are contingent on the productivity, use, or disposition of the intangible.
The general source guideline in Section 865(a) pertains to the noncontingent obligations for the sale of intangible property, sourcing the sale to the location of the seller’s residence. The upfront license fee is being paid by Y to X in exchange for worldwide rights to build up, commercialize, market and sell the underlying drug.