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BNA Taps Senior Treasury Officials for Cost Share Regulations Conference

NEWS RELEASE

Contacts:
Mark Carrington
(703) 341.5880
mcarrington@bna.com

Arlington, Va. (March 9, 2009) – Two months after the release of temporary regulations on cost sharing designed to curb migration of valuable intangible property offshore, senior Treasury and Internal Revenue Service officials engaged with private sector attorneys in an in-depth discussion of the regulations February 19, 2009 at The Present and Future of Cost Sharing conference sponsored by BNA Tax & Accounting and Alston & Bird LLP.

Panelists addressed all aspects of the new cost sharing arrangements, under which related parties pool research costs of developing intangibles in exchange for rights to portions of what is developed without paying royalties.

Rita McWilliams, managing editor of BNA Tax & Accounting’s Transfer Pricing Report, said that the conference showed, "a wealth of different perspectives about how the temporary cost sharing regulations would work in practice," and noted "challenges ahead for taxpayers when cost sharing arrangements are scrutinized at audit." The topic is especially interesting to companies, such as those in the high-technology and pharmaceutical industries, many of which are experiencing audits of their cost sharing arrangements.

Topics covered included:

• When and how the new administrative requirements will apply, especially for preexisting arrangements;
• When to use the various methods for valuing the contributed intangibles;
• Acceptable means for dividing rights in to-be-developed intangibles;
• Use of income versus a cash flow approach;
• Requirements for seeking an advance pricing agreement;
• What to expect on audit; and
• How the IRS will apply the periodic adjustment mechanism

Panelists included Patricia Chaback, the IRS's industry director for the Communications, Technology & Media group, also the issue owner executive for cost sharing; IRS Associate Chief Counsel International Steven Musher; Robert Weissler, a senior attorney in the IRS's APA Program; Kenneth Christman, an attorney in Branch 6 and one of the principal authors of the cost sharing regulations; Michael McDonald, an economist in Treasury's Office of Tax Analysis; Janice Lucchesi, vice president of tax in North America for the Dutch-parented company Akzo Nobel Inc.; Craig Jones, tax director of Dow AgroSciences LLC in Indianapolis; and Timothy Reichert, an economist with Duff & Phelps LLC in Denver who has authored articles on cost sharing and intellectual property.

Full coverage of the conference appears in the March 5 issue of BNA Tax Management's Transfer Pricing Report. To order the BNA Tax and Accounting Center’s analytical library of Transfer Pricing Portfolios written by expert practitioners and the biweekly Transfer Pricing Report, got to: http://www.bnatax.com/tm/tppl.htm or call 800.372.1033

About BNA Tax & Accounting
BNA Tax & Accounting is the foremost source of news, analysis, and practice tools for tax attorneys, estate planners, accountants, and corporate tax and financial accounting professionals. For more than 50 years, BNA Tax & Accounting has offered practitioners expert insights and guidance on every significant issue in tax planning and financial accounting. Written by practitioners for practitioners, BNA’s award-winning Portfolios offer topic-driven, in-depth guidance on transactions designed to help tax professionals achieve new levels of excellence and client service. Visit BNA Tax & Accounting online at www.bnatax.com.

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BNA is the leading independent publisher of print and electronic news and information for professionals in business and government. BNA produces more than 300 news services, including the highly respected Daily Labor Report, U.S. Law Week,and Daily Report for Executives. Visit BNA online at www.bna.com