(Second Edition)

Kenneth L. Port,  Jay Dratler, Jr.,  Faye M. Hammersley, Esq.,  Terence P. McElwee,
Charles R. McManis, and Barbara A. Wrigley

On-Line Problem Supplement
Copyright © 2005   Carolina Academic Press.   For permission, see CMI.

Chapter 12

Problem 13:  Minimizing Tax Liability and Using
Intellectual Property Holding Companies

1.  Amend the license agreement between Contair and Assist for the VRS technology (Chapter 4), to include a clause that minimizes Contair's tax liability.  What additional steps would need to be taken in order to minimize Kuruma's individual tax liability?

2.  Taking into account the list of IP assets that you generated from Chapter 2, provide counsel to Contair on the advisability of forming an IHC to help Contair minimize its state income tax.  If you conclude that forming an IHC would be advantageous to Contair, how would you go about forming the IHC and maintaining it on a going-forward basis to ensure the deductibility of expenses paid to the IHC?

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