Taxes and IP Issues (RECORDING)
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Intercompany transactions involving the exchange of intellectual property are coming under heavy scrutiny from government tax authorities. Transfer pricing transactions involving the exchange of intellectual property are viewed as a commercial transaction that will create a tax liability to the enterprise. This session will discuss transfer pricing best practices, including organization structures, valuations and the agreements that need to be put in place to help IP professionals support their organizations’ transfer pricing teams.
John Cheek
Vice President, Intellectual Property & Legal Operations; Chief Intellectual Property Counsel
Tenneco Inc.
John Cheek is Vice President & Chief Intellectual Property Counsel for Tenneco Inc., a Fortune 200 designer, manufacturer, and marketer of automotive products for original equipment and aftermarket customers. Prior to joining Tenneco in 2017, Mr. Cheek was a senior IP leader at Caterpillar Inc. for nearly 20 years, where he served in IP leadership roles in the United States and Europe. Mr. Cheek received an undergraduate degree in Mathematics from Wabash College and completed additional undergraduate studies in Physics and Mechanical Engineering . He received a J.D. from the University of Dayton and an MBA from the University of Chicago’s Booth School of Business and has lectured on intellectual property strategy and management at the Kellogg School of Management at Northwestern University. He currently serves as President of the Association of Corporate Patent Counsel (ACPC), on the Board of Directors of the Intellectual Property Owners Association (IPO), and on the Board of Directors of the IPO Education Foundation.
James Ferguson
Partner
Mayer Brown LLP
James R. Ferguson is a partner with Mayer Brown LLP, where he focuses his practice on intellectual property, complex commercial litigation and international arbitration. He represents companies in the pharmaceutical, medical device, financial services, information technology and biotechnology industries in cases involving license disputes, patent claims, joint ventures, IT disputes and many other issues. Jim also counsels companies on patent licensing structures, particularly structures involving multi-national affiliates.
Megan Hall
Partner
Eversheds Sutherland (US) LLP
Megan Hall is a partner at Eversheds Sutherland (US) LLP. She advises multinational corporations on international tax matters, including the tax aspects of acquisitions, mergers, internal restructurings and business formations. She has designed plans and led teams to complete international restructurings in advance of a spin-off of a division, initial public offering and acquisition by private equity. She is experienced in post-transaction integration and reporting, including implementing global transfer pricing strategies. Megan also advises employers in connection with tax-related immigration issues unique to global workforces. She provides cross-border tax planning related to short and long-term assignments, including the applicability of SOFAs. She advises on employer withholding obligations, employee exemptions from withholding due to visa status and has efficiently resolved employer withholding tax disputes with the Internal Revenue Service. Megan has advised US chemical companies for more than a decade and is a frequent presenter and author on the Superfund chemical excise taxes. Prior to joining Eversheds Sutherland, Megan served as a law clerk to The Honorable Marvin J. Garbis, United States District Court for the District of Maryland.
David Lane
Associate Patent Counsel
Johnson & Johnson
David Lane is Associate Patent Counsel at Johnson & Johnson.