In a Chief Counsel Advice Memorandum (CCA 202132009), the United States (US) Internal Revenue Service (IRS) concluded that an affiliated group's joint and several liability for the payment of a branded prescription drug (BPD) fee is not solely determinative in deciding whether the remitting member may exclude any reimbursement of the fee from its gross income. The IRS provided several factors that should be considered in determining whether the remitting member benefits from the payment of the fee and, therefore, may not exclude the reimbursement from its gross income.FactsTaxpayer is a US corporation and member of an affiliated group that...