COST - Deloitte: Cost-Sharing Arrangements and PCT Payments: 2017 US Tax Law Impacts genuinely caters to the multistate tax needs of its member companies. Providing cutting edge educational programs and publications, acting as a clearing house for SALT resources, taking amicus positions on important SALT court cases and otherwise lobbying and weighing in on leading SALT legislation."
Planning considerations, such as reverse CSAs and CSA swaps.
The extent to which PCT payments might be eligible for the foreign derived intangible income (FDII) tax rates.
Use of the acquisition price method (APM) as a way of calculating PCT payments, including various technical valuation issues with the APM.
Participants will explore the complex calculations and analyses required for CSAs and PCT payments.