Determining Taxable Income in Connection with a Cost Sharing Arrangement: A Review and Analysis of the Temporary Cost Sharing Regulations

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.

AUTHOR

Wolters Kluwer Tax and Accounting

Wolters Kluwer Tax and Accounting is a leading provider of software solutions and local expertise that helps tax, accounting, and audit professionals research and navigate complex regulations, comply with legislation, manage their businesses and advise clients with speed, accuracy and efficiency. Wolters Kluwer Tax and Accounting is part of Wolters Kluwer N.V. (AEX: WKL), a global leader in information services and solutions for professionals in the health, tax and accounting, risk and compliance, finance and legal sectors. We help our customers make critical decisions every day by providing expert solutions that combine deep domain knowledge with specialized technology and services. Wolters Kluwer reported 2016 annual revenues of €4.3 billion. The company, headquartered in Alphen aan den Rijn, the Netherlands, serves customers in over 180 countries, maintains operations in over 40 countries and employs 19,000 people worldwide. Wolters Kluwer shares are listed on Euronext Amsterdam (WKL) and are included in the AEX and Euronext 100 indices. Wolters Kluwer has a sponsored Level 1 American Depositary Receipt program. The ADRs are traded on the over-the-counter market in the U.S. (WTKWY).

All stories by: Wolters Kluwer Tax and Accounting