William Byrnes' Tax, Wealth, and Risk Intelligence

William Byrnes (Texas A&M) tax & compliance articles

Posts Tagged ‘cost sharing arrangement’

Cost-Sharing Post TCJA | The Fiona Show sponsored by Crossborder AI Solution for Transfer Pricing

Posted by William Byrnes on April 14, 2020

Cost-sharing arrangements are subjective at best—even by transfer pricing standards. Over the years, major tech-companies like Xilinx, Amazon, Altera, and now Facebook, have all been victims of their own interpretations of cost-sharing regulations that have been written, re-written, modified, and in some cases, grandfathered to previous or even temporary versions. And that’s all not to even mention the Tax Cuts and Jobs Act. So, does the world have a right to be a little perplexed? We’d say so.

Listen to our recorded webinar in front of a live audience of transfer pricing counsel from large U.S. MNEs representing 10 major industries.  The webinar explores the mis-understood history of cost-sharing, the impact of Covid-19 on stress testing intra-group risk allocation amongst its global value chain, and the likely impact of the TCJA on future cost-sharing arrangements.

Episode 41: Cost-Sharing Post TCJA

Interested in tax risk management, technology, and analytics?  Check out what Texas A&M is doing this Summer International Tax Risk Management Summer Zoom Courses May 18 – July 3 interested in transfer pricing and tax risk management? Check out Texas A&M’s transfer pricing courses


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