Final IRS Cost Sharing Rules Change Little From Earlier Proposal

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Final cost sharing regulations issued by IRS contain few changes from the temporary rules released in December 2008, but add examples and other language to clarify various technical aspects of the temporary version. Like the 2008 temporary rules and the proposed version issued in 2005, the final rules follow the investor model principle, which practitioners have criticized as generating overly large buy-in payments for intangibles contributed by the U.S. parent company in the arrangements.