SECTION 9. COMMENTS

.01 Comments Requested . The Treasury and IRS request comments on the definition of a QPCLA and whether the Net Consideration Method also should extend to other types of cross licensing arrangements and, if so, under what conditions.

For example, comments are requested on the tax treatment of cross licensing arrangements for the joint development of intellectual property discussed in comments in response to Notice 2006–34. Such cross licensing arrangements are not within the definition of a QPCLA because the parties to such arrangements also engage in more than de minimis licensing or other transfer of other intangible property pursuant to the arrangements. The Treasury and IRS are considering, however, whether it may be appropriate to extend similar tax treatment to those arrangements. See § 1.482–7(g)(2) and (g)(8), Examples 4 and 5.

.02 Submission of Comments . Written comments may be submitted to the Office of Associate Chief Counsel (International), Attention: John E. Hinding (Revenue procedure 2007–23), CC:INTL:6, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC 20224. Alternatively, taxpayers may submit comments electronically to revenue procedure.comments@irscoun- sel.treas.gov . Please include “Revenue Procedure 2007–23” in the subject line of any electronic communications. Comments will be available for public inspection and copying.