Section 482; Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction

Summary: ↑

This document contains corrections to final regulations (TD 9568), which were published in the Federal Register on Thursday, December 22, 2011 (76 FR 80082), relating to section 482 and methods to determine taxable income in connection with a cost sharing arrangement.

Background
Need for Correction
Correction of Publication

For further information contact: ↑

Joseph L. Tobin at (202) 435-5265 (not a toll-free number).

Supplementary information: ↑

Background ↑

The final regulations that is the subject of these corrections are under section 482 of the Internal Revenue Code.

Need for Correction ↑

As published, final regulations (TD 9568), contains errors which may prove to be misleading and are in need of clarification.

List of subjects in 26 cfr part 1 ↑

Income taxes, Reporting and recordkeeping requirements.

Correction of Publication ↑

Accordingly, the final regulations (TD 9568) that was the subject of FR Doc. 2012-895 is corrected to read as follows:

Part 1—income taxes ↑

Paragraph 1. The authority citation for part 1 continues to read in part as follows:

Authority: ↑

26 U.S.C. 7805 * * *

Part 1—[corrected] ↑

Par. 2. Section 1.482-7 is amended by:

1. Revising the title of the table of paragraph (g)(4)(viii), Example 2 (ii).

2. Revising the fourth sentence of paragraph (g)(4)(viii), Example 3 (ii).

The revisions read as follows:

§ 1.482-7 * * * * *

(g) * * *

(4) * * *

(viii)Examples.* * *

Example 2. ↑

* * *

(ii) * * *

“INCOME METHOD APPLICATION NUMBER:”

* * * * *

Example 3. ↑

* * *

(ii) * * * FS determines that the discount rate that would be applied to determine the present value of income and costs attributable to its participation in the licensing alternative would be 12.5% as compared to the 15% discount rate that would be applicable in determining the present value of the net income attributable to its participation in the CSA (reflecting the increased risk borne by FS in bearing a share of the R & D costs in the cost sharing alternative). * * *

* * * * * Guy R. Traynor,

Federal Register Liaison, Legal Processing Division, Publication & Regulation Branch, Associate Chief Counsel (Procedure and Administration).

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Details

Publication Date:: Tuesday, February 14, 2012
Document Number:: 2012-3351
Publishing Agency:: Department of the Treasury
Dates:: This correction is effective on February 14, 2012 and is applicable beginning December 22, 2011.
Effective Date:: 02/14/2012
Action:: Correcting Amendment.
Entry Type:: Rule
Other Formats:: html | text | pdf
Page:: 8143-8144 (2 pages)

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