On 5 June 2019, the U.S. IRS published a Memorandum dated 21 May 2019 on the formal withdraw of Directive LB&I-04-0118-004. Directive LB&I-04-0118-004 was issued on 12 January 2018 and provided that, until a Service-wide position is finalized, examiners are to stop developing adjustments to cost sharing arrangements (CSAs) based on changing the taxpayer’s multiple reasonably anticipated benefits (RAB) shares to a single RAB share when subsequent platform contribution transactions (PCT…