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.
Evaluating the “next best” alternative when determining a reasonable royalty for patent infringement damages
In the context of a reasonable royalty analysis for patent infringement damages, accused infringers often consider their next best alternative when evaluating...