IRS changes its approach to intangible assets

The recent passage of the Tax Cuts and Jobs Act (TCJA) in the USA has resulted in significant changes to the advice and guidance being given by tax advisors around the world, including in the Channel Islands.

Among other considerations around economic substance, the increasing of inheritance tax threshold and slashing of corporate tax rates, the Inland Revenue Service (IRS) has also turned its attention to taxing profits created from US intellectual property and indeed on from other intangible assets – wherever in the world they may be created.

Linus Ostberg (link:, director with Moore Stephens’ US tax service practice, highlighted this in the most recent issue of BL Magazine .

Linus said that an operating business in the UK with US owners in the Channel Islands has to be aware of these rules and see whether or not there should be some restructuring.

To read the full article pick up a copy of BL Magazine, or see it online here:

We’re also fortunate that Linus will be visiting the Channel Islands in March to discuss this and other matters with our clients and contacts. Get in touch if you would like to know more: or