The collection of information related to the IRS's assessment of whether a cost sharing arrangement is valid, and whether each participant's share of costs is proportionate to the participants share of benefits, and whether arm's length compensation has been paid to those participants providing external contributions such that an appropriate return is provided to those participants for putting their funds at risk to a greater extent than the other participants.
US Code:
26 USC 6103
Name of Law: Confidentiality and disclosure of returns and return information
US Code:
26 USC 482
Name of Law: Allocation of income and deductions among taxpayers
US Code: 26 USC 1.482-7 Name of Law: Allocation of income and deductions among taxpayers
The temporary regulations provide for an expansion of the documentation requirements in proposed § 1.482-7 in order to address perceived inadequacies in the requirements as well as to ensure compliance with the revised guidance on the valuation of PCT payments as set forth in temporary § 1.482-7(g). These changes increased the burden hours to 9,350.
$0
No
No
Uncollected
Uncollected
No
Uncollected
Kenneth Christman 202 435-5265
No
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.