The U.S. IRS has released an international practice unit on Cost Sharing Arrangement with Stock Based Compensation. The general overview of the practice unit includes the following:
Under the U.S. cost sharing rules, parties under common control may enter into a cost sharing arrangement (CSA) which allows the parties to share the costs and risks of developing one or more intangibles (cost shared intangibles) in proportion to each party’s share of reasonably anticipated benefits (RAB) expect…