Show navigation

Live Webinar

90-minute live streaming program
  • August 16
  • 1:00 - 2:30 pm EST

Cost Sharing Agreement Regulations

August 16

Gain information on how to use cost sharing agreements as an effective tax planning tool.

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 in detail, identify the provisions that have been called into question, and discuss any impacts the OECD BEPS initiative may have on cost sharing arrangements. This information is beneficial for individuals who are unfamiliar with cost sharing arrangements or who want to understand cost sharing arrangements in the current legal landscape.

Learning Objectives

- You will be able to define the relevant provisions of cost sharing arrangements.

- You will be able to describe the requirements of complying with the cost sharing regulations.

- You will be able to discuss the different transfer pricing valuation methods outlined in the regulations.

- You will be able to explain the impact BEPS may have on cost sharing arrangements.

Purchase Options

More Program Information

Why Lorman?

Over 30 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 1.482-7(a)
  • Brief History of Cost Sharing Arrangements (CSAs)
  • General Rules
Cost Sharing Arrangement 1.482-7(b)
Platform Contributions 1.482-7(c)
Intangible Development Costs 1.482-7(d)
  • General Rules
  • Altera and SBC
Reasonable Anticipated Benefits Share 1.482-7(e)
Changes in Participation Under a CSA 1.482-7(f)
Transfer Pricing Methods for PCTs 1.482-7(g)
  • Best Method Analysis
  • Comparable Uncontrolled Transaction Method
  • Income Method
  • Acquisition Price Method
  • Market Capitalization Method
  • Residual Profit Split Method
  • Amazon
Form of Payment Rules 1.482-7(h)
  • Fixed vs. Contingent
IRS Adjustments 1.482-7(i)
  • Periodic Trigger Rules
Administrative Requirements and Transition Rules 1.482-7(k), -7(m)
  • Contractual Requirements
  • Documentation Requirements
  • Accounting Requirements
  • Reporting Requirements
  • Transition Rules
OECD BEPS Impact on Cost Sharing
Purchase Options

More Program Information

Why Lorman?

Over 30 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

Live Webinar Registration

  • AIPB 1.5
     
  • This program is acceptable for 1.5 CPEC(s) towards the CB designation through the American Institute of Professional Bookkeepers (AIPB).
     
  • 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 State Bar of Arizona does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. 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 Business Center, Inc. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CO CLE 2.0
     
  • This program may qualify for 2.0 credit hours through the Colorado Supreme Court Board of Continuing Legal and Judicial Education through reciprocity. This course is accredited in other jurisdictions such as New Jersey. To receive CLE credit for this program, a home study affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education.
     
  • 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.
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MS CLE 1.5
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.5 credit hours.
     
  • MT CLE 1.5
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.5 CLE credits.
     
  • NC CLE 1.5
     
  • This program has been approved by the North Carolina State Bar Board of Continuing Legal Education for 1.5 CLE hours.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 90 Minutes.
     
  • NJ CLE 1.8
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • 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.
     
  • TN CLE 1.5
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.5 hours of credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of CLE credit.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of credit.
     
  • WI CLE 1.5
     
  • This program has been approved by the Board of Bar Examiners for 1.5 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     
  • CPE 1.8 including Specialized Knowledge 1.8
     
  • Lorman Education Services is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its web site: https://www.nasbaregistry.org/cpas/complaints. For more information regarding administrative policies such as complaint and refund, please contact our offices at 866-352-9539. CPE Credit: Maximum Credit Hours: 1.8 each session (based on a 50 minute credit hour). You must attend at least 50 minutes to obtain credit. Field of Study: Specialized Knowledge for 1.8 hours. Prerequisite: basic knowledge of taxation. Level of Knowledge: Intermediate. Teaching Method: Seminar/Lecture. Advance Preparation: None. Delivery Method: Group Internet Based. Please refer to the information in this brochure for outline, course content and objectives. Upon completion of this course, you will receive a certificate of attendance. Final approval of a course for CPE credit belongs with each state's regulatory board. Please note: In order to receive CPE credit for this course you MUST use the streaming audio option, as well as enable and complete the required progress checks.
     
  • Lorman Business Center, Inc. is a registered provider for CPA CPE through the State Education Department of New York, Sponsor number: 000640. The following course will carry the subject area of Specialized Knowledge and Applications for 1.5 hours.
     
  • Lorman Business Center, Inc. has registered with the Texas State Board of Public Accountancy as a CPE Sponsor. This registration does not constitute an endorsement by the Board as to the quality of our CPE Program. This program qualifies for 1.5 hours of continuing professional education.
     

Who should attend?

This live webinar is designed for accountants, CPAs, CFOs, controllers, accounts payable professionals, tax managers, presidents, vice presidents, business owners and managers, bookkeepers and attorneys.

Purchase Options

More Program Information

Why Lorman?

Over 30 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

Joy Dasgupta

Joy Dasgupta

DLA Piper LLP (US)

  • Principal economist in the tax department at DLA Piper LLP (US)
  • Assists large multinationals and major law firms in transfer pricing and tax planning matters
  • Has worked on a variety of transfer pricing and tax planning projects involving pricing of intercompany transactions applying the arm's-length standard; among these have been the transfer of intangible property, buy-in of intangible assets, cost sharing arrangements, determination of royalty rates for license arrangements, and the structuring of intangible property holding companies
  • Has worked on business restructurings, valuation of unique intangible assets, and tax related valuation matters
  • Industry experience includes the high tech, medical devices, pharmaceuticals, automotive and telecommunication industries; has also assisted clients with audit defense and transfer pricing related controversies
  • Prior industry experience includes semiconductors design and electronic design automation, where he has held positions in product development and marketing
  • Currently works in transfer pricing, business and intangible property valuation and other valuation-related projects, applying his understanding of technology and his economic analysis experience
  • Also has experience in business litigation cases involving patent infringement in the technology sector and in litigation support in the pharmaceutical and telecom industries
  • Can be contacted at 650-833-2114 or [email protected]
Mumi Hemrajani

Mumi Hemrajani

DLA Piper LLP (US)

  • Associate at DLA Piper LLP in International Tax Practice
  • Concentrates her practice on transfer pricing and international tax planning
  • Before joining DLA Piper, she served as a General Attorney in the Office of the Associate Chief Counsel International at the Internal Revenue Service
  • During her tenure, she provided legal advice on cases involving transfers of intangibles offshore, buy-in payments and cost sharing arrangements, distressed asset/debt tax shelters, DISC and FSC issues, ETI eligibility and the ETI transition rules, treaty interpretation, sourcing, and blocked income rules. She assisted in the publication of the section 482 final cost sharing regulations (TD 9568) and served as the drafting attorney on related bullet regulations (TD 9569 and TD 9630)
  • In addition, she served as the Branch 6 point of contact for EOI requests that involve transfer pricing issues
  • J.D. degree, Georgetown University Law Center; LL.M. in taxation, Georgetown University Law Center; B.A. degree, Brown University
  • Can be contacted at 650-833-2027 or [email protected]
Eric D. Ryan

Eric D. Ryan

DLA Piper LLP (US)

  • Of counsel and co-chair, Transfer Pricing Practice at DLA Piper LLP (US)
  • Concentrates in international tax planning, transfer pricing, post-merger integration of legal entities, and operations and tax controversy
  • More than 25 years of experience, both as a tax partner advisor and an internal corporate tax director, on key international tax structuring issues. His clients are primarily in the high technology industry, including software, hardware, semiconductors and life sciences companies
  • Experience includes advising clients in choice of location for their operations; conducting direct negotiations for tax holidays in countries such as Switzerland, Singapore and others; advising on intercompany arrangements that minimize Subpart F and similar tax issues; and advising on intercompany economic terms that seek to maximize profits in appropriate jurisdictions
  • Advises on the use of holding companies, the valuation of transfer of tangible and intangible property, and the establishment of cost-sharing operations
  • Experienced in developments of advice pricing agreements (APAs) and intercompany debt and equity
  • Pro Bono Coordinator for the East Palo Alto office
  • On behalf of the Government of the United States Virgin Islands, he worked to obtain the favorable guidance from the U.S. Treasury and Internal Revenue Service ultimately contained within Notice 2006-76, relating to the qualification of certain e-commerce business models for income tax exemptions in the USVI
  • Can be contacted at 650-833-2118 or [email protected]
Purchase Options

More Program Information

Why Lorman?

Over 30 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.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today
With This Course

Access to all training products for one year
$699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.

Product ID: 400056
Published 2017
Purchase Options

Available in Multiple Formats

Purchase this course and learn on your schedule!