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Cost Sharing Agreement Regulations

OnDemand Webinar (92 minutes)

Gain information on how to use cost sharing agreements as an effective tax planning tool.Recent Tax Court cases have called into question the validity of certain provisions of the cost sharing regulations. This topic will walk through the current cost sharing regulations in detail, identify the provisions that have been called into question, and discuss any impacts the OECD BEPS initiative may have on cost sharing arrangements. This information is beneficial for individuals who are unfamiliar with cost sharing arrangements or who want to understand cost sharing arrangements in the current legal landscape.

Authors

Joy Dasgupta, DLA Piper LLP (US)
Mumi Hemrajani, DLA Piper LLP (US) Eric D. Ryan, DLA Piper LLP (US)

Agenda

Overview §1.482-7(a)

• Brief History of Cost Sharing Arrangements (CSAs)

• General Rules

Cost Sharing Arrangement §1.482-7(b)

Platform Contributions §1.482-7(c)

Intangible Development Costs §1.482-7(d)

• General Rules

Altera and SBC

Reasonable Anticipated Benefits Share §1.482-7(e)

Changes in Participation Under a CSA §1.482-7(f)

Transfer Pricing Methods for PCTs §1.482-7(g)

• Best Method Analysis

• Comparable Uncontrolled Transaction Method

• Income Method

• Acquisition Price Method

• Market Capitalization Method

• Residual Profit Split Method

Amazon

Form of Payment Rules §1.482-7(h)

• Fixed vs. Contingent

IRS Adjustments §1.482-7(i)

• Periodic Trigger Rules

Administrative Requirements and Transition Rules §1.482-7(k), -7(m)

• Contractual Requirements

• Documentation Requirements

• Accounting Requirements

• Reporting Requirements

• Transition Rules

OECD BEPS Impact on Cost Sharing

Additional Formats

Audio & Reference ManualMore Info