Final Cost-Sharing Rule Describes New Application of Income Method

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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).
 
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