A recent IRS directive on the use of multiple “reasonably anticipated benefit” shares in a cost sharing arrangement withdrew a 2018 directive on the same issue, recognizing that an IRS Chief Counsel memorandum had cemented an IRS-wide position.
IRS examiners are now directed to assess the appropriateness of using single or multiple reasonably anticipated benefit (RAB) shares for a cost sharing arrangement (CSA) based on the facts at hand.
Read a June 2019 report [PDF 76 KB] prepared by the KPMG member firm in the United States: New Directive Formally Acknowledges Adoption of IRS Wide Position on Multiple RAB Shares in CSAs
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