California - License to copy and install software is intangible and royalties from that license must be sourced using costs of performance

December 2012

Overview

A California appellate court concluded that royalties received from the license to replicate and install software during the manufacture of computers by original equipment manufacturers (OEMs) are receipts from intangible property and must be sourced based on the location of the preponderance of the costs of performance.

Contact us

Peter Michalowski
National SALT Practice Leader
Tel: +1 (646) 471 5259
Email

Follow us