Computer Software And Internet Sales And Licenses
The Export Disc Corporation Computer Software And Internet Sales And Licenses
The IC-DISC has been approved as an acceptable tax planning entity for the export of American produced computer software and programs as early as 1985. In 1998, a very detailed set of Treasury Regulations were issued that have added certainty to this area of the law.
Before the issuance of the Software Regulations, there was uncertainty about the taxation of computer program transactions. Computer programs did not fit traditional tax principles. Computer programs are usually sold pursuant to “license” or “user agreements”. A computer program transaction is unlike a sale of a physical object since the value of the program copy far exceeds the value of the physical medium on which it is transferred. Computer programs, in fact are transferred electronically. Often, there is no physical medium at all.
For purposes of determining the applicability of the DISC to computer software exports, two key analyses are often required. First, (1) is the software “export property” for DISC purposes and (2) is the software product’s source of income “from without the U.S.”? Is the product for use, consumption or sale without the U.S.?
If you have additional questions on this topic – please contact us.
Alfred Zucaro Jr – U.S. Immigration Law
Immigration and nationality law concerns the movement of people across international boundaries into the United States.
This practice focuses on giving people the ability to live, work and be active in the United States either on a temporary or permanent basis.
Both individuals and businesses need migration strategies depending on what their primary objectives are. For example, an individual might need a strategy on his/her behalf or may have been moved by a business to fulfill the needs of the business. The migration strategy is the plan of action within legal parameters that will satisfy the demands of the client.
The basis for immigration law is:
- to re-unify families and
- to protect jobs for American workers.
Why is immigration and related issues becoming increasingly important for individuals and companies?
On a very basic level, companies have labor needs and people need jobs. Immigration provides individuals with a path to help them accomplish their goals. It also provides local and international businesses with a way to find qualified people (workers) and move them into position. (e.g. an international firm may need scientists or researchers with highly specialized knowledge/expertise).
In the fields of international tax matters and immigration it is the legal planning and precision advice in advance that insures that commercial endeavors are completed at minimum tax costs and that personal lives are minimally disrupted. However, we have been around long enough to know that the world of international commerce is not a perfect world.
The principals of U.S. Taxation and Immigration Law know how to apply their knowledge, experience and relationships just as effectively to resolve the legal obstructions that arise and often lead to failure if not dealt with quickly. We are just as good in cleaning up a legal mess as we are at making sure they do not happen in the first place.
Alfred “Al” Zucaro Jr. is one of the principals of U.S. Taxation and Immigration Law, LLC. He is also South Florida’s most captivating voices on international trade and commerce, especially in relation to immigration law and migration strategy. Since 1986, Zucaro has practiced immigration and nationality law. Zucaro’s leadership skills and expertise extend well beyond the courtroom.
CONTACT ALFRED ZUCARO, United States Immigration Law
6018 S.W. 18th Street, Suite C-1
Boca Raton, FL 33433
(561) 368.1113 telephone
(561) 368.1349 fascimilie
Richard S. Lehman, Esq. – U.S. Taxation
Richard S. Lehman is a graduate of Georgetown Law School and obtained his Master’s degree in taxation from New York University.
He has served as a law clerk to the Honorable William M. Fay, U.S. Tax Court and as Senior Attorney, Interpretative Division, Chief Counsel’s Office, Internal Revenue Service, Washington D.C.
Mr. Lehman has been practicing in South Florida for more than 35 years. During Mr. Lehman’s career his tax practice has caused him to be involved in an extremely wide array of commercial transactions involving an international and domestic client base.
You can read more about Richard Lehman at his personal legal website site: www.LehmanTaxLaw.com
CONTACT Richard S. Lehman, Esq., United States Taxation
6018 S.W. 18th Street, Suite C-1
Boca Raton, FL 33433
(561) 368.1113 telephone
(561) 368.1349 fascimilie