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IRS Withdraws Directive on Reasonably Anticipated Benefits in Cost Sharing Arrangements

07 June 2019

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Approved Changes

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United States

On 5 June 2019, the U.S. IRS published a Memorandum dated 21 May 2019 on the formal withdraw of Directive LB&I-04-0118-004. Directive LB&I-04-0118-004 was issued on 12 January 2018 and provided that, until a Service-wide position is finalized, examiners are to stop developing adjustments to cost sharing arrangements (CSAs) based on changing the taxpayer’s multiple reasonably anticipated benefits (RAB) shares to a single RAB share when subsequent platform contribution transactions (PCTs) are added to an existing CSA. --- May 21, 2019 Control Number: LB&I-04-0519-005 MEMORANDUM FOR ALL LARGE BUSINESS AND INTERNATIONAL DIVISION EMPLOYEES FROM: Douglas W. O’Donnell /s/ Douglas W....