Extract to table

The regulations establish a detailed framework of requirements that must be satisfied for an arrangement to qualify as a CSA and to avoid adjustment by the IRS under IRC § 482

Each participant must be a controlled taxpayer within the meaning of Treas

482-1(i)(5), must reasonably anticipate benefits from exploitation of the cost-shared intangibles in its assigned territory, and must substantially comply with the provisions of the CSA

This provision establishes the requirement that each controlled participant's share of IDA costs must be proportional to its share of reasonably anticipated benefits from the cost-shared intangibles

482-7(b)(1) requires that each controlled participant in a CSA satisfy three conditions: (i) the participant must be a "controlled taxpayer" within the meaning of Treas

482-1(i)(5), meaning it must be one of two or more organizations, trades, or businesses owned or controlled directly or indirectly by the same interests; (ii) the participant must "reasonably anticipate" deriving benefits from exploitation of the cost-shared intangibles in its assigned territory; and (iii) the participant must "substantially comply" with the material provisions of the CSA throughout the relevant period