Extract to table

482-1(d) establishes the "best method rule," which provides that 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

482-7(b), a QCSA must meet the following requirements: (i) two or more controlled participants must join in the arrangement; (ii) each participant must have a reasonable expectation of deriving benefits from the cost-shared intangibles; (iii) each participant must bear a share of the intangible development costs ("Coss") that is consistent with its share of reasonably anticipated benefits ("RABs"); and (iv) the arrangement must be documented contemporaneously

482-7(e) provides that each controlled participant's share of coss must be proportionate to its share of RABs from the exploitation of cost-shared intangibles

The RAB shares must be determined on a basis that is consistent and reasonable across all participants

When a controlled participant contributes pre-existing resources, capabilities, or rights to the CSA, a platform contribution transaction ("PCT") is required to compensate the other participants for the value contributed

person transfers intangible property to a foreign corporation in certain transactions described in IRC § 332, 351, 354, 356, or 361, the transferor shall be treated as having sold such intangible property in exchange for payments contingent on the productivity, use, or disposition of the property