Cost-sharing arrangements and PCT payments: 2017 US tax law impacts Bookmark has been added
Cost-sharing arrangements and PCT payments: 2017 US tax law impacts
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.