Extract to table

The principal requirements for a qualified CSA under the regulations include: (a) Eligibility of Controlled Participants: Each controlled participant must reasonably expect to derive benefits from the intangible development activity

(b) Scope of Intangible Development Activity: The CSA must define the intangible development activity that is the subject of cost sharing

(c) Reasonably Anticipated Benefits: Each participant's cost-sharing percentage must be determined based on that participant's share of the reasonably anticipated benefits from the intangible development activity

(d) Platform Contribution Transactions: When a controlled participant makes pre-existing resources, capabilities, or rights available to the CSA, the other participants must make arm's-length payments (platform contribution transaction payments) to compensate for such contributions

Both prongs must be satisfied

The proposed § 482 adjustments, to the extent they reduce PBI's income, would correspondingly reduce PPC's GILTI inclusion — an interaction that must be accounted for in computing the correct tax liability