Gain a better understand cost sharing arrangements in the current legal and tax environment.
Cost-sharing 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 cost-sharing regulations. This topic will walk through the current cost-sharing 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 cost-sharing arrangements. This course is beneficial for individuals who are new to cost-sharing arrangements or who want to understand cost-sharing arrangements in the current legal and tax environment.
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Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on September 20, 2022.
Call 1-866-352-9540 for further credit information.
- AIPB 1.5
- This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
- AK CLE 1.5
- Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
- AL CLE 1.5
- This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
- AR CLE 1.5
- This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
- Arizona CLE 1.5
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.5
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
- CT CLE 1.5
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
- GA CLE 1.5
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.5 CLE hours.
- MO CLE 1.8
- This course qualifies for self-study CLE credit in Missouri.
- ND CLE 1.5
- North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.5 hours of CLE credit.
- NH MCLE 1.5
- NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 91 Minutes.
- NM CLE 1.5
- This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.5 hours of credit.
- NV CLE 1.5
- This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
- RI CLE 1.5
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
- VT CLE 1.5
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Mumi Hemrajani
DLA Piper LLP (US)
- International Tax Attorney at DLA Piper LLP
- Concentrates in international tax planning, transfer pricing, and post-merger integration of IP and legal entities
- Prior to joining DLA Piper, served as a General Attorney in the Office of the Associate Chief Counsel International at the Internal Revenue Service providing legal advice on cases involving transfers of intangibles offshore, buy-in payments, and cost-sharing arrangements
- Assisted in the publication of the section 482 final cost-sharing regulations (TD 9568) in 2011 and served as the drafting attorney on related bullet regulations (TD 9569 and TD 9630) in 2012
- Contact Information: 1 202 799 4371. E-mail: [email protected]
Madhura Maitra
DLA Piper LLP (US)
- Managing Director at DLA Piper LLP (US)
- Practice focuses on transfer pricing and tax valuation for companies in various industries
- Over ten years of transfer pricing experience and has worked on a variety of transfer pricing and tax planning projects involving pricing of intercompany transactions applying the arm’s-length standard
- Extensive experience in building complex models related to cost-sharing arrangements as well as valuation of intangibles in the context of cost-sharing arrangements
- Received Ph.D. in Economics (Specialization in International Trade) from Columbia University
- Authored articles related to international trade and transfer pricing
- Can be contacted at 650-833-2463 or [email protected]
Wei Wang
DLA Piper LLP (US)
- Managing Director at DLA Piper LLP (US)
- Concentrates in transfer pricing, including intercompany policy design and implementation, tax restructuring and supply chain optimization, IP migration, and general compliance and documentation
- Charter Financial Analyst
- M.A. in International Economics and Finance, Brandeis International Business School
- Can be contacted at 650-833-2125 or [email protected]
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