Background
Ocean Tomo, a part of J.S. Held experts have been retained in global tax litigations and related investigations by both US and foreign tax authorities and taxpayers subject to tax investigations or disputes.
Engagement
Across the engagements, Ocean Tomo provided deep analyses of company IP assets, licensing practices, royalty rates, and valuations. These matters encompassed many types of IP asset classes, including patents and technology, trademarks and brands, software, and data – and covered many sectors – highlighting Ocean Tomo and J.S. Held’s significant breadth of industry and technical expertise.
Results
One matter involved a ten-figure litigation surrounding the IP licensing practices of an international social media company.
Outside the United States, Ocean Tomo experts have also worked on behalf of tax authorities and taxpayers, including in a landmark Australian tax litigation involving the analysis of a multinational beverage brand’s inter-company licensing arrangements and associated compensation structures and amounts.