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by philiphodgen
4480 days ago
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Do not transfer IP to the US mother ship before you have thought it out. You can transfer IP into the USA but once you have done that all of the profit generated from that IP worldwide will be subject to US tax. And if you ever want to transfer the IP out of the USA it will be treated as a sale. The worst I ever saw was one of those online poker sites. To move out of the USA they had to move their IP to a new foreign corporation. The appraised value of the domain name was $6,000,000. That's a $6,000,000 income item. Pay tax on that at 34%, baby. For day-to-day business operations you will have the normal level of business brain damage. Complexity is a mathematical constant. |
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So I presume that it would be the best to only delay the IP transfer from Europe to US just before the investment and formal links (US company owning 100% of European company) might be already in place?