The Internal Revenue Service (IRS), as part of its continuing effort to reduce paperwork and respondent burden, invites the general public and other Federal agencies to comments on the existing final regulations (TD 9088) dealing with the treatment of compensatory stock options under the transfer pricing rules of section 482 of the US Internal Revenue Code (IRC). The notice was published in the Federal Register on 2 October 2017.
The regulation was issued 26 August 2013 providing guidance regarding the application of the rules of section 482 governing qualified cost sharing arrangements. These regulations provide guidance regarding the treatment of stock-based compensation for purposes of the rules governing qualified cost sharing arrangements and for purposes of the comparability factors to be considered under the comparable profits method.
