Sell franchise rights: retained significant power = ordinary income; full transfer = cap gains.
IRC §1253 governs franchise, trademark, and trade name transfers. If transferor retains 'significant powers, rights, or continuing interest' (approval rights on subletting, standards, territories) — payments are ORDINARY income. Fully release those powers — payments qualify for CAPITAL GAINS treatment. Structure sale docs carefully; contingent payments generally stay ordinary. Also affects franchisee — payments can be ordinary deduction over franchise life.
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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.
Cost-share IP dev between US parent + foreign sub — future IP owned by low-tax jurisdiction.