The Resource Deconstructing the income method, resurrecting cost sharing

Deconstructing the income method, resurrecting cost sharing

Label
Deconstructing the income method, resurrecting cost sharing
Title
Deconstructing the income method, resurrecting cost sharing
Creator
Subject
Language
eng
Summary
This article demonstrates that the value of platform intangibles, as determined by the income method, is inconsistent with the long-standing definition of fair market value, does not provide payors with a rate of return commensurate with the risks that they bear, and does not give effect to the highly uncertain nature of research and development. It describes an alternative method for valuing intellectual property that is not substantially developed at the outset of a cost sharing arrangement, and proposes that the IRS simply recharacterize cost sharing arrangements as a series of bilateral licenses between payees and payors when payees' platform contributions are substantially developed
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 20 (2011),
http://library.link/vocab/creatorName
King, E. (Elizabeth)
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • intellectual property
  • fair market value
  • cost sharing arrangement
Label
Deconstructing the income method, resurrecting cost sharing
Instantiates
Publication
Label
Deconstructing the income method, resurrecting cost sharing
Publication

Library Locations

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      52.3736660 4.9336932
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