Live Webinar

90-minute live streaming program
  • September 20
  • 1:00 - 2:30 pm EST

Cost Sharing Agreement Regulations

September 20

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.

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.

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Why Lorman?

Over 35 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 35 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).
     
  • 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 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, LLC. 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.
     
  • 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.
     
  • IN CLE 1.5 (Pending)
     
  • This program has been submitted to the Indiana Commission for Continuing Legal Education for Distance Education for participating attorneys. Application Pending.
     
  • MO CLE 1.8
     
  • This program has been approved by the Missouri Bar for 1.8 hours of CLE.
     
  • MS CLE 1.5 (Pending)
     
  • This program has been submitted to the Mississippi Commission on Continuing Legal Education. Approval pending.
     
  • NC CLE 1.5 (Pending)
     
  • ND CLE 1.5
     
  • This program has been reviewed by the North Dakota Commission for Continuing Legal Education and approved for 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 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.
     
  • 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.
     
  • OH CLE 1.5 (Pending)
     
  • This course has been submitted to the Supreme Court of Ohio Commission on Continuing Legal Education for 1.5 CLE hours. Approval pending.
     
  • 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 (Pending)
     
  • This program has been submitted as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.5 hours of credit.
     
  • VA CLE 1.5 (Pending)
     
  • This program has been submitted to the Virginia Mandatory Continuing Legal Education Board for 1.5 CLE credit hours.
     
  • 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.
     
  • 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 Taxes 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: www.nasbaregistry.org. 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: Taxes 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.
     

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.

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Why Lorman?

Over 35 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

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

Madhura Maitra

DLA Piper LLP

  • Senior Managing Economist at DLA Piper LLP
  • Assists multinationals in transfer pricing and tax planning matters in various industries
  • 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
  • Contact information: 1 650 833 2463. E-mail: [email protected]
Wei Wang

Wei Wang

DLA Piper LLP (US)

  • Managing Director at DLA Piper LLP
  • Concentrates in transfer pricing, including intercompany policy design and implementation, tax restructurings 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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Over 35 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.

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Product ID: 410068
Published 2022
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