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Cost Sharing Agreement Regulations, Ohio CLE 1.5 (Pending)
Ohio
Tuesday, September 20, 2022
1:00 PM ET - 2:30 PM ET
OH MCLE 1.5 (Pending)
OH CPE 1.8
$199.00
Use Discount Code R5380628 for 20% off entire purchase from Lorman Education Services.
Course Overview
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.
Agenda
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
Presenter:
Mumi Hemrajani
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