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CATEGORIES:CSTC Academy
SUMMARY:CSTC Academy - Intellectual Property
DESCRIPTION:
Tuesday, August 4, 2020
8:30 AM to 10:10 AM
Topic: Intellectual Property
Speaker:
Curt Harrington, Attorney at Law
2 Federal Tax Law H
ours
IRS: 18QC1-T-01362-20-O
CTEC: 1000-CE-4756
Course Description:
Intellectual Property and its taxat
ion over the past 21 years has experienced decline. To understand it, we wi
ll review the advantages of the past, the causes of decline, and how to par
tially deal with the decline as our clients look to preserve their rights t
o make-up some of the losses in the decline and position for some modest re
turn of rights in the future. Part of game is to have our clients package,
preserve, and control IP rights in a way that benefits our clients with som
e aspects of the advantages that once operated nearly automatically.
Knowledge Level: Intermediate
Learning Object
ives:
#1: Attendees will learn the different types of intellectu
al property rights, how they are created, how they can be protected, (or no
t), and what to look for at the end of the trail for each:
(1) Introdu
ction & Understanding the Negative Nature of IP and thinking inversely.
(2) Overview of Intellectual Property Categories & Process for mo
ving forward.
(3) Tax Treatment of Patents, Copyrights, & Trademar
ks - then, now and future?
(4) The "Prolific Inventor" model diminishe
s in favor of collaboration?
(5) Was it a bad idea to focus on small s
tartup inventors & instant capital gains?
#2: Attendees will get an id
ea of how a policy disfavoring pure intellectual property control is likely
to remain in one form or another from now on, and why, and that the IP own
er will have to work harder and faster to try and keep ahead. The hunt for
the perfect invention, the perfect business just gets more difficult.
#3: A
ttendees will be left to think in terms of techniques, checklists and appro
aches that an IP owner could employ and expect resistance from everyone.
(1) Carrot & Stick for Licensing & Provisions for Inducing Actio
n.
(2) How to help inventive taxpayers keep more of the money they ear
n.
(3) Insurance: Offensive & Defensive Patent Insurance, and trad
emark insurance, indemnification.
(4) planning & using the whole o
f the design patent - trademark life cycle.
(5) Diversification of Ent
ities & Diversification to Reduce Risk & Run Lean.
(6) Use Bus
iness Credits and the Threat of relocating to obtain some tax help.<
/p>
Curt Harrington, Attorney at Law
, EA
This may be the only firm that combine
s the power of deep highly technical engineering & patent law, with the
tax planning and loss mitigation abilities of a tax specialization attorne
y.
As a short version of
an introduction, Curt assists in start-up or trouble modes: Start-up mode includes: Trademark, Patent, Entity Selec
tion, & Operating Optimization, and evaluating licensing for instant ca
pital gain capability versus ordinary income, versus self-employment income
. Trouble mode includes: Eva
luating IRS & FTB Non-Compliance Errors & Planning (civil & cri
minal); Tax Debt Solutions: Asset Loss Reduction & Transfer Planning; L
imiting Current & Future Liability. Details of help
and expertise to support your project includes advice relating to the foll
owing:
(1) Tax effect is neces
sarily independent of patentability (using the trade secret rules on sale t
o enhance instant cap gains on sale);
(2) After the Tax Cuts and Jobs Act of 2017 the picture for
patents, trade secrets and copyrights has changed.
(3) He provides guidance to help maximize patentable nature of such invent
ions by characterizing the scientific nature of the project and to reduce/e
schew the purely internal IT (non-scientifically oriented "spread sheet" or
"html" functions);
(4) He mak
es the IT persons aware that the additional PTO board hurdle of finding sec
tion 101 statutory subject matter should be an early planning guide. It is
believed that the elimination of capital asset status in the Tax Cuts and J
obs Act of 2017 was an eventual backlash over the greater focus on internet
advertising. Tax patents from several years ago didn't help.
(5) His background as a Basic/Fortr
an programmer, coupled with graduate degrees in Chemical Engineering &
Electrical Engineering, Law, Taxation, & Business put him in a position
to help IT inventors steer clear of trouble and remain to the extent possi
ble in capital gains control.
(6) Assisting with trademark selection to: (a) avoid bleed losses fr
om selection of a descriptive name, (b) set the stage for least disruptive
examination and a quicker publication and ultimate issuance, (c) maximize f
uture value and tax yield and personal liability reduction through selectio
n of a holding structure, (d) minimizing litigation that often must be capi
talized and result in a cost of $1.50 for every dollar spent defending the
mark, (e) act as a memory multiplier and impression puzzle to multiply any
advertising return, (f) the use of trademarks and trade secrets to secure a
higher price ultimate sale of the business by maximizing goodwill, & (
g) the use of all intellectual property to securitize sale or other transfe
r of the business.
(7) Licensing techniques to sel
ect taxation of licensing income, as well as a carrot & stick technique
to encourage minimum unit sales while reserving return of the license wher
e the licensee does not perform.
(8) Using insurance, ent
ity selection & diversification of purposed units to maximize tax dedu
ctions, reduce risk and to help evaluate and reconfigure the distribution t
opology.
(9) Performing an analysis between the "Prolific
Inventor vs. Unitary Business" continuum to find the best fit for the futu
re activities of the entrepreneur
(10) Selection of domicile, operating, warehousing, and manufacturing l
ocation decisions for tax reduction both for income and sales tax; planning
to minimize unwanted sales & income tax surprise events in future.
(11) Help in planning for
unexpected bankruptcy for both licensor and licensee in order to vary the i
pso facto clause treatment, preserve the value of the business, consider po
tential bifurcation and differentiation of patent, trade secret and tradema
rk rights in a way which will further be consistent with the target tax tre
atment of the licensor / licensee goals.
(12) Help for foreign patent holders in receiving royalti
es from the United States, reduction of the 30% (Fixed, Determinable, or Pe
riodic Income) FDAP tax to a treaty rate if possible, and the establishment
of a withholding agent and the filing of tax returns in the United States
for U.S. source income reporting, especially to result in refunds against t
he FDAP.
(13) Analyzing
and advising on foreign involvement in U.S. business from loans, to joint
ventures, to FIRPTA involvement; and advising on the triggering of FBAR and
FATCA.
(14) Characterizing, to the extent possibl
e, computer inventions with their analog and pre State Street Bank equivale
nts, including emphasizing analog signals, open-ended math functions, inter
active feedback, scientific instrumentation and statistical decision makin
g.
(15) Conflict identification and isolation is a major
goal, in order to identify and help the taxpayer client, reemphasizing that
others can subvert and compromise the civil and criminal liability of the
taxpayer client through adverse position as well as unintended criminal con
spiracies.
(16) Tax problems including tax and non-tax de
bt, Substitute for Return (SFR), providing long range analyses for bankrupt
cy* (*Debt Relief Agency where actually hired to file bankruptcy, and only
after voluminous acknowledged teachings),and offer in compromise options, e
xpected ratio of debt types and, orderly advantageous payoff of tax debts a
s beneficial.
(17) Attorney-cl
ient privilege planning through encouragement of taxpayers to file their ow
n returns to avoid conspiracy potential, limited engagements with tax prepa
rers, paper filing to effect disclosure where electronic filing stifles dis
closure; and the effect of taking action on tolling limitation statutes.
(18) Formation and Operation of Nonprofit entities a
nd Nonprofit Advising from small nonprofits with state-only recognition to
federal recognition; Planning for effective use of federal donation deducti
ons, small low budget nonprofit statutory liability mechanisms, insurance,
efficient use of funds, and the unbalanced limits of nonprofit and business
interaction, and application of government rules for nonprofit intellectua
l property.
(19) Ta
x Specialization Continuing Education Provider No. 15203<
br />
CONTACT:info@cstcsociety.org or 949-715-4192
DTSTAMP:20240328T213107
DTSTART;TZID=America/Los_Angeles:20200804T083000
DTEND;TZID=America/Los_Angeles:20200804T101000
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