If a controlled taxpayer that is not a controlled participant contributes to developing a cost shared intangible, as defined in section (j)(1)(i) of this section, it must receive consideration from the controlled participants under the rules of § 1.482-4(f)(4) (Contribution to the value of an intangible owned by another). Such consideration will be treated as an intangible development cost for purposes of paragraph (d) of this section.
§ 1.482-7(a)(3)(i) Contribution to a CSA by a controlled taxpayer that is not a controlled participant.
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By Internal Revenue Service
Category: US IRC Section 482 on Transfer Pricing, § 1.482-7 Methods to determine taxable income in connection with a cost sharing arrangement | Tag: CCA/CSA, CCA/CSA - methods for pricing, CCA/CSA changes in the membership, CCA/CSA contributions, CCA/CSAs for development, Contribution to value of intangibles, Intangibles
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