Bloomberg Tax
April 23, 2021, 4:09 PM

Firms Shuffle Intangible Assets Abroad Despite U.S. Tax Break

Michael Rapoport
Michael Rapoport
Senior Reporter, Bloomberg Tax

Some U.S. multinational companies stand to save billions in taxes by shuffling their patents, trademarks, and other intellectual property around overseas among subsidiaries—a practice that Democrats hope to discourage with new tax-overhaul proposals.

Companies like Dell Technologies Inc., Uber Technologies Inc., and Electronic Arts Inc. are generating huge future tax benefits—and often boosts to their current earnings—by moving intellectual property from one offshore subsidiary to another. Dell has generated $4.9 billion in tax benefits through such transfers, according to its securities filings. Electronic Arts has generated $1.8 billion.

Companies say the moves are designed to better align their structure ...

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