Proposed IRS Regulations and Cost-Sharing Arrangements

A “Cost-Sharing Arrangement” (CSA) is a method of sharing the costs and risks of the development of intangibles. Each participant in the CSA must bear its share of cost and risk and in return will own whatever results from the arrangement. New regulations of cost-sharing arrangements under section 482 of the Internal Revenue Service (IRS) Tax Code provide for the treatment of cost-sharing arrangements between controlled participants to share the costs and risks of intangible development in proportion.

The following questions have been addressed in this article:

What Are Cost-Sharing Arrangements (“CSAs”)?
What Prompted The IRS To Propose Changes In Regulations Related To Cost-Sharing Arrangements?


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