Ryan Finley explains why the Tax Court’s confirmation of the cost-sharing regulations’ validity was more important than its ...

Recent testimony in the U.S. Tax Court's Facebook v. Commissioner trial highlighted a problem with the U.S. cost-sharing regulations, which establish valuation rules for a type of related-party ...

The ruling underscores the need for companies to provide robust and defensible valuations of intangible assets, one partner ...

The Internal Revenue Service has issued new regulations on cost-sharing arrangements for multinational companies that provide some extra flexibility in transfer pricing schemes. The Treasury and the ...

A transfer-pricing regulation that requires related entities to share the cost of employee stock ... Furthermore, the IRS’s conclusion in the regulations that stock-based compensation should be ...

The court ruled that Xilinx Inc. v. Commissioner, 125 T.C. 37 (2005) held that, under 1995 cost-sharing regulations, controlled entities entering into qualified cost-sharing agreements need not share ...