Integrating The IP Of New Technologies Global Tax And IP Risks (Podcast)

This episode of Tech Talks outlines why intercompany licensing—clear ownership, licensees, and exclusive rights—is vital for operations and litigation standing. It flags exit tax and transfer pricing exposure tied to DEMPE functions and valuation disputes, which can cause double taxation without strong documentation. Mayer Brown partners Jim Ferguson and Jason Osborn, along with host Julian Dibbell, review enforcement nuances for patents, trade secrets, trademarks, and copyrights, and the need to update employment agreements to assign future inventions to the right affiliate. Their takeaway: align structures with business reality and coordinate IP and tax teams early.

Episode Show Notes

00:02 Introduction to Integrating the IP of New Technologies
2:03 Intercompany licensing basics
5:06 Exit taxes/economic ownership
6:56 DEMPE and valuation/TP risk
9:47 Patent standing
10:52 Trade secrets/trademarks/copyrights
14:20 Pre-close playbook
17:13 Tax and IP Team Collaboration

To learn more about this topic, see our recent article Integrating the IP of New Technologies: Global Tax and IP Risks.

Visit us at mayerbrown.com

Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.

© Copyright 2025. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.