Code of Federal Regulations (Last Updated: July 5, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter A - Income Tax |
Part 1 - Income Taxes |
Adjustments |
§ 1.482-4T - Methods to determine taxable income in connection with a transfer of intangible property (temporary).
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(a) through (f)(3)(i)(A) [Reserved] For further guidance,
see § 1.482-4(a) through (f)(3)(i)(A).(B)
Cost sharing arrangements . The rules in this paragraph (f)(3) regarding ownership with respect to cost shared intangibles and cost sharing arrangements will apply only as provided in § 1.482-7T.(f)(3)(ii) through (f)(6) [Reserved] For further guidance,
see § 1.482-4(f)(3)(ii) through (f)(6)(g)
Coordination with rules governing cost sharing arrangements . Section 1.482-7T provides the specific methods to be used to determine arm's length results of controlled transactions in connection with a cost sharing arrangement. This section provides the specific methods to be used to determine arm's length results of a transfer of intangible property, including in an arrangement for sharing the costs and risks of developing intangibles other than a cost sharing arrangement covered by § 1.482-7T. In the case of such an arrangement, consideration of the principles, methods, comparability, and reliability considerations set forth in § 1.482-7T is relevant in determining the best method, including an unspecified method, under this section, as appropriately adjusted in light of the differences in the facts and circumstances between such arrangement and a cost sharing arrangement.(h)
Effective/applicability date . The provisions of paragraphs (f)(3)(i)(B) and (g) of this section are generally applicable on January 5, 2009.(i)
Expiration date . The applicability of this section expires on or before December 30, 2011.