Generally, royalty income which is paid for the right to use intangibleproperty (such as a likeness) is sourced where theproperty is used or is granted the privilege of being used.
To the contrary, considering the inherently transient nature of intangibleproperty and the practical difficulties in running down creditor-dodging debtors who are unwilling to voluntarily pay their debts, creditors should be given the widest possible latitude to select their forums and shop law so as to satisfy the debts owed to them.
R.5: The element is inscribed as an Important Intangible Folk Cultural Property on the national inventory maintained by the Agency for Cultural Affairs.
Alternatively, the proposal would tax certain intangibleproperty related income on a current basis at a rate of 15%, whether derived directly by a U.S. corporation or by a foreign subsidiary.
In the 21st Century economy, intangible assets like intellectual property comprise an increasing percentage of corporate valuation, making it imperative that these assets are protected in any new trade deal.