Tag: Timing of CST allocation

§ 1.482-7(i)(2)(iii) Timing of CST allocations.

If the Commissioner makes an allocation to adjust the results of a CST, the allocation must be reflected for tax purposes in the year in which the IDCs were incurred. When a CST payment is owed by one controlled participant to another controlled participant, the Commissioner may make appropriate allocations to reflect an arm’s length rate of interest for the time value of money, consistent with the provisions of § 1.482-2(a) (Loans or advances) ...
Allocation by Commissioner, Audit, CCA/CSA, CCA/CSA - methods for pricing, Cost Contribution Arrangement (CCA), Cost Sharing Arrangement (CSA), CST allocation, Pre-existing intangibles, Timing of CST allocation, Valuation, Valuation of intangibles