Tag: CCA/CSA documentation
§ 1.482-7(k)(2)(iii)(B) Production of documentation.
Each controlled participant must provide to the Commissioner, within 30 days of a request, the items described in this paragraph (k)(2) and paragraph (k)(3) of this section. The time for compliance described in this paragraph (k)(2)(iii)(B) may be extended at the discretion of the Commissioner ... Read more
§ 1.482-7(k)(2)(iii)(A) Coordination with penalty regulations.
See § 1.6662-6(d)(2)(iii)(D) regarding coordination of the rules of this paragraph (k) with the documentation requirements for purposes of the accuracy-related penalty under section 6662(e) and (h) ... Read more
§ 1.482-7(k)(2)(ii) Additional CSA documentation requirements.
The controlled participants to a CSA must timely update and maintain documentation sufficient to – (A) Describe the current scope of the IDA and identify – (1) Any additions or subtractions from the list of reasonably anticipated cost shared intangibles reported pursuant to paragraph (k)(1)(ii)(B) of this section; (2) Any cost shared intangible, together with each controlled participant’s interest therein; and (3) Any further development of intangibles already developed under the CSA or of specified applications of such intangible which has been removed from the IDA (see paragraphs (d)(1)(ii) and (j)(1)(i) of this section for the definitions of reasonably anticipated cost shared intangible and cost shared intangible) and the steps (including any accounting classifications and allocations) taken to implement such removal; (B) Establish that each controlled participant reasonably anticipates that it will derive benefits from exploiting cost shared intangibles; (C) Describe the functions and risks that each controlled participant has undertaken during the term of the CSA; (D) Provide an overview of each controlled participant’s business segments, including an analysis of the economic ... Read more
§ 1.482-7(k)(2)(i) In general.
The controlled participants must timely update and maintain sufficient documentation to establish that the participants have met the CSA contractual requirements of paragraph (k)(1) of this section and the additional CSA documentation requirements of this paragraph (k)(2) ... Read more