INCOME TAX

T.D. 9568, page 499. Final regulations under section 482 of the Code provide guidance on the determination of and compensation for all economic contributions by all controlled participants in connection with a cost sharing arrangement (CSA) in accordance with the arm’s length standard. The regulations address issues that have arisen in administering the cost sharing regulations.

T.D. 9573, page 498. Final regulations update the regulations under section 104 of the Code to reflect statutory amendments limiting the section 104(a)(2) exclusion to damages for personal physical injuries or physical sickness and to delete the “tort or tort-type rights” test.