Final Cost-Sharing Rule Describes New Application of Income Method

For over 50 years, Bloomberg Tax’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...

The Internal Revenue Service Aug. 26 issued final cost-sharing rules (T.D. 9630) describing a new specified application of the income method in Treasury Regulations Section 1.482-7(g)(4) for directly determining the arm's-length charge for platform contribution transactions or buy-in payments.
In the final rules, IRS adopted without change proposed regulations (REG-145474-11) from December 2011 that provided supplemental guidance on applying the IRS's income method.
The proposed rules were part of a larger package of cost-sharing rules (T.D. 9569).
For full access to this article, please register for a free trial to Daily Tax Report®.  

Request Daily Tax Report