TD 9568, Methods to Determine Taxable Income in connection with a Cost Sharing Arrangement - IRC Section 482

The purpose of Internal Revenue Code (IRC) section 482 is to ensure taxpayers clearly reflect income attributable to controlled transactions and to prevent avoidance of taxes regarding such transactions. IRC section 482 places a controlled taxpayer on a tax parity with an uncontrolled taxpayer by determining true taxable income. Previously approved, TD 9568 (76 FR 80082) published December 22, 2011, contained final regulations regarding methods to determine taxable income in connection with a cost sharing arrangement under section 482 of the Internal Revenue Code (Code). The final regulations address issues that had arisen in administering the cost sharing regulations. The final regulations affect domestic and foreign entities that enter into cost sharing arrangements described in the final regulations.

The latest form for TD 9568, Methods to Determine Taxable Income in connection with a Cost Sharing Arrangement - IRC Section 482 expires 2021-04-30 and can be found here.