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U.S. IRS Publishes Memorandum on Multiple RAB Shares and Subsequent PCTs

|Approved Changes|United States
United States

The U.S. IRS has published a Memorandum from the Office of Chief Counsel concerning the regulations for cost sharing arrangements (CSA), which require that cost sharing participants share the costs and risks of developing intangibles by engaging in cost sharing transactions (CST), resulting in CST Payments that are required to be determined by reference to the share of reasonably anticipated be…

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