Integrating the IP of New Technologies Global Tax and IP Risks
This episode of Tech Talks outlines why intercompany licensing—clear ownership, licensees, and exclusive rights—is vital for operations and litigation standing. It flags exit tax and transfer pricing exposure tied to DEMPE functions and valuation disputes, which can cause double taxation without strong documentation. Mayer Brown partners Jim Ferguson and Jason Osborn, along with host Julian Dibbell, review enforcement nuances for patents, trade secrets, trademarks, and copyrights, and the need to update employment agreements to assign future inventions to the right affiliate. Their takeaway: align structures with business reality and coordinate IP and tax teams early.
Episode Show Notes
00:02 Introduction to Integrating the IP of New Technologies
2:03 Intercompany licensing basics
5:06 Exit taxes/economic ownership
6:56 DEMPE and valuation/TP risk
9:47 Patent standing
10:52 Trade secrets/trademarks/copyrights
14:20 Pre-close playbook
17:13 Tax and IP Team Collaboration
To learn more about this topic, see our recent article Integrating the IP of New Technologies: Global Tax and IP Risks.
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