The 2026 IFA Congress Award-winning work relates to the Main Subject of the 2026 IFA Congress in Melbourne: Taxation of Royalties for the Use of, and Gains from the Sale of, Intellectual Property/Intangibles.
Global IFA Congress Award Winners of 2026: Jonathan Seebach & Philipp Riehm
Title of work: From Germany with Love: Comparative Law Thoughts on the 40th Anniversary of Boulez v. Commissioner
Short description: The winning article analyses the 1984 Boulez v. Commissioner case, addressing the distinction between royalty and service income in a German-American cross-border context from a German comparative law perspective. As a result of the analysis, the authors suggest legislative solutions that interact with the role of internal intellectual property law in attributing income sources. The article highlights the need to look beyond tax law and address how underlying intellectual property law can create and resolve international double taxation.
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