Experts in CRA’s Transfer Pricing Practice worked with the finance and tax team on a cross-border transaction structure to give a growing life sciences company the ability to migrate IP at a later date if a global expansion were successful. The economic modeling included the valuation of an option on specified rights to the IP portfolio and considered financial, cash, and tax consequences of a range of business scenarios in support of executive decision making.
Recent federal circuit opinions address the economic domestic industry requirement
Under Section 337, a complainant must demonstrate that a domestic industry relating to each asserted patent either exists or is in the process of being...