The U.S. IRS has published a Memorandum from the Office of Chief Counsel concerning the regulations for cost sharing arrangements (CSA), which require that cost sharing participants share the costs and risks of developing intangibles by engaging in cost sharing transactions (CST), resulting in CST Payments that are required to be determined by reference to the share of reasonably anticipated benefits (RAB). The Memorandum addresses a request for legal advice regarding the recurring issue of whether the cost sharing regulations in § 1.482-7 prohibit the use of multiple RAB shares within a single CSA. The request arose specifically in response...