Speaking Engagement

Ofer Lion to Co-Present at the October 2015 AHLA Tax Issues for Health Care Organizations Meeting

Monetizing Intellectual Property: Tax-Exempts and the Tax Treatment of IP Revenue


Arlington, VA
On Thursday, October 8, 2015, Ofer Lion will co-present “Monetizing Intellectual Property: Tax-Exempts and the Tax Treatment of IP Revenue” at the AHLA Tax Issues for Health Care Organizations Meeting.
The presentation will discuss:
  • The IP developed by health care organizations, including clinical and business information technology applications, may be of considerable value to other exempt organizations, commercial businesses, and governments
  • IP includes traditional rights (patents, copyrights, etc.) and non-traditional assets (access to captive audiences, endorsements, sponsorships, naming opportunities, etc.)
  • Structures for generating revenue through IP include direct manufacturing and/or marketing and selling derivative products or services, costsharing agreements, taxable corporate subsidiaries, single member LLCs, and technology transfer organizations
  • Tax consequences of a variety of contractual arrangements for monetizing IP by a transfer of rights to related or unrelated persons, including fees and royalties from licensing, royalties versus service fees, cross-licensing agreements, royalties from sponsored research, and sales of IP or derivative products
  • Critical tax issues, including (i) technology transfer transactions and tax-exempt bond or other contractual covenants, (ii) research income derived by “scientific” organizations, including sponsored research, (iii) how to comply with “private benefit” regulations and ensure fair market value, and (iv) restrictions on the ability to offset UBI with losses from exempt activities and through the use of net operating losses