1.482-4T—Methods to determine taxable income in connection with a transfer of intangible property (temporary).
(B) Cost sharing arrangements.
The rules in this paragraph (f)(3) regarding ownership with respect to cost shared intangibles and cost sharing arrangements will apply only as provided in § 1.482-7T.
(g) Coordination with rules governing cost sharing arrangements.
Section 1.482-7T provides the specific methods to be used to determine arm's length results of controlled transactions in connection with a cost sharing arrangement. This section provides the specific methods to be used to determine arm's length results of a transfer of intangible property, including in an arrangement for sharing the costs and risks of developing intangibles other than a cost sharing arrangement covered by § 1.482-7T. In the case of such an arrangement, consideration of the principles, methods, comparability, and reliability considerations set forth in § 1.482-7T is relevant in determining the best method, including an unspecified method, under this section, as appropriately adjusted in light of the differences in the facts and circumstances between such arrangement and a cost sharing arrangement.
(h) Effective/applicability date.
The provisions of paragraphs (f)(3)(i)(B) and (g) of this section are generally applicable on January 5, 2009.