The sourcing of receipts from the rental, lease, or license of
intangible property to business customers is based on the location in which the intangible is used.
It is a stretch to suggest that USPAP's definition of
intangible property (intangible assets) means "leases" when it says "contracts.
Businesses benefit from patent boxes by transferring their
intangible property to these entities or developing it in these entities and then exploiting the
intangible property through these entities.
When there has been a complete transfer and sale of
intangible property rights, sales are to be sourced (1) if the purchaser used the property in a single state, to the state where the purchaser exclusively used the property at the time of the purchase; (2) based upon the "extent of the purchaser's location in this state as compared to the purchaser's locations everywhere"; (3) based upon a "reasonable approximation"; or (4) according to the billing address of the purchaser.
The ATB exception, however, does not apply to certain types of property, including any
intangible property described under Sec.
Property policies are not the only forms that address whether
intangible property is covered.
According to the filings, which are nearly identical: "Without any change in law or regulations, the Tax Division began to include the value of
intangible property in the .
This decision could become a powerful tool for plaintiff lenders seeking to attach a defendant's
intangible property (e.
Stenton Leigh Group professionals perform a variety of business valuations, including fairness opinions, goodwill (SFAS 141 and 142),
intangible property valuations, and stock options and warrant valuations (SFAS 123C).
Intangible property is property that cannot be seen or felt--such as customer records, patents, trademarks and copyrights.
In an appeal to the Appellate Division, Second Circuit, he sought reinstatement of his conversion cause, and Nationwide countered that a conversion claim cannot be based on the misappropriation of electronic records and data because New York does not recognize a cause of action for
intangible property.
While the new regulations focus on intercompany services aspect, they also importantly apply to
intangible property to the extent it is imbedded in such services.
