(ii) If research and development are successful, the lozenge form will provide fertilizer more efficiently to crops and less fertilizer will be needed to achieve the same effect on plant growth. It is expected that the form of the fertilizer pellet will be sold at a premium price over the fertilizer powder, based on savings on the amount of fertilizer to be used. If research and development are successful, the cost of producing pellet fertilizers should be about the cost of producing powdered fertilizers and the same cost for FP and USS. FP and USS operate at about the same market level and sell much of their fertilizer to independent distributors. (ii) coordination with the penal regime. The documents in paragraph (j) (2) (i) of this section correspond to the main documents covered by Section 1.6662-6 (d) (2) (iii) (B) with respect to a qualified cost-sharing agreement. (2) Limitation of endowments. The District Director does not grant endowments in connection with a qualified cost-sharing agreement, unless it is necessary to increase the share of each controlled participant in the costs (as defined at point (d) of the intangible evolution under the qualified cost-sharing agreement, based on its share of the reasonably expected benefits to be attributed to such a development. , in accordance with the rules of this section. When a controlled tax officer acquires an interest in intangible assets from another controlled subject (except for the assumption of a portion of the costs of the development of the intangible), the district director may make appropriate endowments to reflect the length of an arm for the acquisition of such a shareholding, articles 1.482-1 and 1.482-4 at 1.482-6. See point g) of this section. Participation in an intangible sector includes all commercially transferable interests whose benefits are value-exposed.
The definition of an immaterial value. In recent years, the IRS has expressed concern about what it sees as an abusive practice by taxpayers in transferring intellectual property to low-tax areas. To address this issue, the U.S. Treasury issued regulations in 2005 that contained major revisions to the current regulations of Section 482 of the Internal Revenue Code (IRC) for CSAs. (ii) performance measurement. In order to assess the share of a controlled participant in the expected benefits of covered intangible assets, it is necessary to measure the amount of reasonably expected benefits from hedged intangible assets on a consistent basis for all of these participants.