The U.S. IRS has published a Memorandum dated 13 July 2021 from the Office of Chief Counsel concerning Section 482 adjustments for cost sharing agreements with reverse claw-back provisions. This includes guidance in relation to regulations that were upheld by the U.S. Court of Appeals for the Ninth Circuit in a case involving Altera Corp.

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Section 482 Adjustments for Cost Sharing Agreeme…