The Resource Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations

Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations

Label
Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations
Title
Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations
Creator
Subject
Language
eng
Summary
This article examines the proposed regulations issued on 23 August 2005 addressing the treatment of cost sharing arrangements (CSA) between controlled participants. First, it discusses certain policy issues that motivated the IRS and the Treasury to issue the proposed regulations and the "Investor Model", which forms the theoretical foundation of the proposed regulations. Next, it discusses the revised definition of a CSA and certain terms that are essential to understanding that definition. Third, it discusses the proposed regulations' methods for valuing PCT payments, which are analogous to buy-in payments under the current regulations. Fourth, it discusses the circumstances in which the IRS may reallocate share costs or income produced by shared intangibes, including a commensurate with income rule tailored to CSAs. Fifth, it discusses the documentation, reporting and accounting requirements in the proposed regulations. It concludes with a discussion of the transition rules
Citation source
In: Taxes. - Chicago. - Vol. 83 (2005),
http://library.link/vocab/creatorName
  • Chandler, C.J
  • Cope, C.W
  • Zollo, T.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • cost sharing arrangement
  • buy-in payment
  • intangibles
Label
Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations
Instantiates
Publication
Label
Methods to determine taxable income in connection with a cost sharing arrangement : a review and analysis of the proposed cost sharing regulations
Publication

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