Buy dormant C-corp with §382-preserved NOLs — deploy them against your IP royalty stream.
Acquire a dormant C-corp with substantial NOLs (net operating loss carryforwards). §382 limits annual use to (value × long-term tax-exempt rate) after ownership change, but for shell corps with real business continuation, NOLs can shelter 5–20% of income for years. Combine with contributing IP/royalty streams into the acquired corp. NOL brokers (NOLmarket) list qualifying corps. Watch for §269 anti-abuse and §382 built-in loss rules.
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.