Extract to table

Under the best method rule, the arm's-length result of a controlled transaction must be determined under the method that, under the facts and circumstances, provides the most reliable measure of an arm's-length result

When a participant in a CSA makes available pre-existing resources, capabilities, or rights ("external contributions") to the CSA, the other participants must make platform contribution transaction payments to compensate the contributing participant for the value of those contributions

transferor is treated as having transferred the intangible property in exchange for payments contingent on the productivity, use, or disposition of such property, and must include in income for each taxable year amounts that would be commensurate with the income attributable to the transferred intangible

482-7(g)(4)(vi)(F) (the financial projections used in the income method "must be the most reliable projections

WVG notes that while the actual outcome is a useful reference point, it does not determine the appropriate as-of-date valuation; the valuation must be based on what was reasonably anticipated as of July 1, 2012