Cost-share IP dev between US parent + foreign sub — future IP owned by low-tax jurisdiction.
Enter a Qualified Cost Sharing Arrangement (Treas. Reg. 1.482-7) between US parent and controlled foreign subsidiary. Each entity contributes to R&D costs; each owns resulting IP for its territory. Foreign entity's future income streams stay OUT of US tax (subject to GILTI). Popular pre-TCJA (Apple/Google Double Irish); still viable with §962 elections. Requires: written CSA, buy-in payments, ongoing platform contributions.
Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.
Move trademarks/patents to NV/DE holdco, license back to opco, deduct royalties at state level.
Individual inventor selling patent gets LTCG treatment regardless of holding period.
Buy music catalogs at 8–15x annual royalties — 6–12% cash yield + upside.
Sell forward-flow of your royalties for a lump sum — David Bowie's original playbook.
Own your brand personally, license to your C-corp for arms-length royalty.
TCJA forces 5-yr (US) / 15-yr (foreign) amortization of R&D — plan expense timing carefully.
Get 6–14% credit on qualified R&D wages, supplies, contract research — plus state credit stack.
Sell franchise rights: retained significant power = ordinary income; full transfer = cap gains.