(Planning for IP transfers into and out of the US)
The large potential value of IP, as well as the ease of transfer makes IP one of the most effective tools for achieving tax efficiency.
Correctly treated, and provided the norms of transfer pricing are observed, the development, sale, and licensing of IP typically yields significant tax benefits, especially when the IP is licensed into or out of the US.
In many cases the appropriate transfer and treatment of IP can position a group for sale or listing in addition to maximizing after tax earnings. See Transferring IP?