Publication
Infringement risk relating to creation and use of the output of a generative AI system
Where the Output of a generative AI system is the same or substantially similar to a third party’s copyright work
Foreign nongrantor trust for US beneficiaries: dos and don’ts
United States | Publication | April 2022
The throwback tax is the US tax law’s main tool for discouraging tax-free accumulation of income by foreign non-grantor trusts for US beneficiaries. Its complex rules are a dangerous minefield that should be avoided. This article reviews the operation of the throwback tax rules, and assesses the effectiveness of this trust anti-deferral regime in various fact patterns. It also discusses how the trust anti-deferral regime interacts with the US law’s foreign corporation anti-deferral regime, another minefield.
Download the Oxford Academic's Trusts & Trustees reprint
Co-head of Tax, United States
Email
bill.cavanagh@nortonrosefulbright.com
Recent publications
Publication
Is the output of the generative AI system protected by intellectual property rights?
The approach and requirements for intellectual property rights to subsist in computer-generated works vary from jurisdiction to jurisdiction.
Publication
Infringement risk relating to training a generative AI system
Generative AI systems are trained using vast amounts of data, often taken from sources in the public domain that may be protected by copyright or other intellectual property rights, such as, in the UK and EU, a database right.
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