-19- results consistent with an arm's length result, and to clarify that under the best method rule, the provisions of � 1.482-7 set forth the applicable method with respect to qualified cost sharing arrangements. Id. at 49000. Sections 1.482-1 and 1.482-7, Income Tax Regs., were modified as follows: SEC. 1.482-1. Allocation of Income and Deductions Among Taxpayers. * * * * * * * (2) * * * Section 1.482-7 provides the specific method to be used to evaluate whether a qualified cost sharing arrangement produces results consistent with an arm’s length result. * * * * * * * SEC. 1.482-7. Sharing of Costs. * * * * * * * (3) Coordination with � 1.482-1.--A qualified cost sharing arrangement produces results that are consistent with an arm's length result within the meaning of � 1.482-1(b)(1) if, and only if, each controlled participant's share of the costs (as determined under paragraph (d) of this section) of intangible development under the qualified cost sharing arrangement equals its share of reasonably anticipated benefits attributable to such development (as required by paragraph (a)(2) of this section) and all other requirements of this section are satisfied. * * * * * * * (2) Stock-based compensation.--(i)* * * a controlled participant's operating expenses include all costs attributable to compensation, including stock-based compensation. * * * stock-based compensation means any compensation provided by a controlled participant to an employee * * * in the form of equity instruments, options to acquire stock (stock options), or rights with respect to (or determined by reference to) equity instruments or stock options, including but not limited to property to which section 83 applies and stock options to which section 421 applies, regardless of whether ultimately settled in the form of cash, stock, or other property.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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