On 4 January 2017, the U.S. IRS published an international practice unit entitled IRC 367(d) Transactions in Conjunction with Cost Sharing Arrangements (CSA). The practice unit covers requirements in relation to the practice of transferring high value intangibles to a related party located in low-tax jurisdictions. In particular, the practice unit looks at the determination and potential aggregation of: The arm's length income (charge) required for the use of intangible property transferred to a CFC under Treas. Reg. 1.367(d); and The arm’s length payment required to be made by a CFC to a U.S. parent in relation to a cost...