In an important article in TAXES—The Tax Magazine®, Charles W. Cope, Thomas M. Zollo and Clark J. Chandler examine the temporary cost sharing regulations addressing a cost sharing arrangement (CSA) among controlled taxpayers. These new regulations took effect upon publication in the Federal Register on January 5, 2009 and will expire on December 30, 2011. The Temporary Regulations should be of interest to a broad range of taxpayers because taxpayers with CSAs must understand the transition rules in the Temporary Regulations in order to amend their written agreements prior to July 6, 2009, and qualify for the benefits offered. These transition rules make most of the provisions of the Temporary Regulations applicable to pre-effective date CSAs that qualify for transition relief.
Wolters Kluwer Tax and Accounting
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