If your company transfers its IP to a foreign jurisdiction through a controlled transaction, the income derived from the transaction could benefit from the foreign-derived intangible income (FDII) provision, for all or part of the consideration. The resulting tax rate would be 13.125%.
Alternatively, if a US-based multinational group repatriates its IP from overseas, the same FDII incentive permits a lower tax rate at 13.125% on profits generated by the US IP until 2026.