IRS Form 1099, 1099-NEC, and Form 1099-MISC: Advanced Issues and Updates

Cost Sharing Agreement Regulations

$199.00

SKU: 410068

Description

Gain a better understand cost sharing arrangements in the current legal and tax environment.
Costsharing arrangements are one of the common sources of transfer pricing controversies. Recent Tax Court cases have called into question the validity of certain provisions of the costsharing regulations. This topic will walk through the current costsharing regulations under the U.S. transfer pricing guidelines in detail, identify the provisions that have been called into question, and discuss impacts of the OECD BEPS initiatives on the structure of costsharing arrangements. This course is beneficial for individuals who are new to costsharing arrangements or who want to understand costsharing arrangements in the current legal and tax environment.

Date: 2022-09-20 Start Time: 1:00 PM ET End Time: 2:30 PM ET

Learning Objectives

* You will be able to define the relevant provisions of cost sharing arrangements.

* You will be able to describe the requirements of complying with the cost sharing regulations.

* You will be able to discuss the different transfer pricing valuation methods outlined in the regulations.

* You will be able to explain the impact BEPS may have on cost sharing arrangements.

Overview of Cost-Sharing Arrangements (“CSA”) (U.S. Treas. Regs. §1.482-7(a))
• Brief History of CSAs
• Example of a Typical Cost Sharing Structure

Cost-Sharing Arrangement
• Rules of CSA (U.S. Treas. Regs. §§§1.482-7(B),(K),(L))
• Contractual Requirements
• Documentation Requirements
• Accounting Requirements
• Reporting Requirements

Treatment of SBC and Altera Court Case

Platform Contributions (“PCTs”) (U.S. Treas. Regs. §1.482-7(C))

Transfer Pricing Methods for PCTs (U.S. Treas. Regs. §1.482-7(G))
• Best Method Analysis
• Comparable Uncontrolled Transaction Method
• Income Method
• Acquisition Price Method
• Market Capitalization Method
• Residual Profit Split Method
• Amazon Court Case

Form of Payment of PCTs (U.S. Treas. Regs. §1.482-7(H))
• Fixed vs. Contingent

Transition Rules (U.S. Treas. Regs. §1.482-7(M)

Current Trends in CSAs

OECD Beps Impact on Cost-Sharing

AIPB ,CLE (Please check the Detailed Credit Information page for states that have already been approved) ,CPE ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.

Mumi Hemrajani-DLA Piper LLP (US), Madhura Maitra – DLA Piper LLP, Wei Wang – DLA Piper LLP (US)