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 ...

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 ...

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 ...