Licensing of Intangible Property

The licensing of
intangible property is a commonplace occurrence in foreign countries.
Choose any type of intangible property and propose a strategy to minimize
or eliminate the tax impact of licensing.
You have been hired
by a U.S. corporation that wants to invest in a foreign corporation
through the transfer of intangible property. Make a recommendation to your
client as to how to transfer the intangible property and thus mitigate or
eliminate the tax impact of the transfer.

Please
keep the bullet point and solution together and make the solution at least a
paragraph long.