Under long-anticipated regulations published by the US Internal Revenue Service (IRS), cost sharing arrangements (CSAs) remain an effective tool that multinational taxpayers can use to efficiently develop and manage ownership of valuable intangible property among subsidiaries. But valuations of pre-existing, platform intangibles contributed to CSAs will be scrutinised by the IRS going forward
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Effective audit management requires more than documentation; it’s the way taxpayers engage that can shape audit direction, manage procedural ambiguity, and preserve options for appeal or litigation
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