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US IRS articulates five-factor test in determining income inclusion of reimbursement payments

|Tax Alerts, National/Federal Taxation, T ...|United States
United States

In a Chief Counsel Advice Memorandum (CCA 202132009), the United States (US) Internal Revenue Service (IRS) concluded that an affiliated group's joint and several liability for the payment of a branded prescription drug (BPD) fee is not solely determinative in deciding whether the remitting member may exclude any reimbursement of the fee from its gross income. The IRS provided several factors that…

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