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Cost Sharing Agreements
- Cost sharing agreement (CSA) is the principal method for transferring intangible
ownership offshore.
- US parents and foreign subsidiary agree to share costs of development of new version
of technology.
- In return for sharing in development costs, each party gets a share of ownership
- US Parent gets US rights, Foreign Sub gets non-US rights.
- Comprehensive CSA regulations issued in 1995.
- Section 367(d) does not apply.
Typical Operating Structure Prior to Migration
Cost Sharing Agreement
Typical Restructured Legal Entities
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