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IP & Royalties

IP Holding Company in Nevada / Delaware (State Tax Play)

Move trademarks/patents to NV/DE holdco, license back to opco, deduct royalties at state level.

Overview

Transfer valuable IP (trademarks, patents, copyrights, software) into a Nevada or Delaware IP holding company. Opco pays arms-length royalty to holdco, deducts at operating-state level. Holdco pays 0% state tax on royalty income (NV/DE domestic). States are attacking (add-back statutes in NY, NJ, MA, IL, etc.), but properly structured with genuine economic substance still works in ~15 states. Federal treatment unchanged.

Best fit
Multi-state businesses with meaningful IPFranchisorsSaaS companies
Estimated impact
5–10% state tax rate applied to royalty base

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.

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