When the owners of a development-stage technology company foresee the prospect of meaningful revenues, their creative focus almost invariably turns to how they can avoid or defer U.S. tax on their upcoming profits. Easy, right? Tax havens with no taxes and nice beaches immediately come to mind along with a dim recollection of articles reporting multinationals paying virtually no U.S. taxes on their foreign income.
The (imagined) plan is simple: The company's valuable intellectual pr...
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