Dbriefs Webcast

Cost-sharing arrangements and PCT payments: 2017 US tax law impacts

Transfer Pricing

February 13 | 2 p.m. ET | 19:00 GMT

Host: Mark Nehoray, partner, Deloitte Tax LLP
1 Overview CPE credit | Taxes

US cost-sharing arrangements (CSAs) and related platform contribution transaction (PCT) payments have historically been complex. How do newly enacted 2017 provisions impact them? We'll discuss:

  • Planning considerations, such as reverse CSAs and CSA swaps.
  • The extent to which PCT payments might be eligible for the foreign derived intangible income (FDII) tax rates.
  • Use of the acquisition price method (APM) as a way of calculating PCT payments, including various technical valuation issues with the APM.

Participants will explore the complex calculations and analyses required for CSAs and PCT payments.

For more insights on further related topics, please click the respective links below: 

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Mark Nehoray

Mark Nehoray

Senior Partner Transfer Pricing | Deloitte Tax LLP

Mark is a senior partner in the Los Angeles office of Deloitte Tax LLP. He is a founding member of Deloitte’s national transfer pricing practice in March 1990, as well as the founding member of its Lo... More

Joe Tobin

Joe Tobin

Principal | Global Transfer Pricing

Joe is a principal in Global Transfer Pricing at Deloitte’s Washington National Tax practice, Deloitte Tax LLP. He specializes in transfer pricing controversy and planning, especially in the area of c... More