Tony Billings accepted for publication in Tax Notes

Mike Ilitch School of Business Professor of Accounting Tony Billings has had a paper accepted for publication in Tax Notes, which is a portfolio of publications with a large readership of practitioners, academics and policymakers alike.

The article, titled “New Guidelines for Cost Sharing of Intangible Development Costs,” was co-authored by Kyun Kim (State University of New York), Billings’ former research assistant.


As the Internal Revenue Service noted in 1988, Congress projected the use of bona fide cost sharing arrangement (CSA) as a proper method of assigning the ownership of intangibles "ab initio" to the intangible user. The article reviews CSAs among related entities typically used by entity partners to develop intangible property considering the Ninth Circuit Appellate Court opinions involving Altera and The article also addresses the recently issued IRS Generic Legal Advice Memorandum (GLAM) guidelines and new OECD guidelines regarding stock-based compensation (SBC). The report stresses the need for CSA partners to assess requirements of true-up payments for reverse claw back provisions involving stock-based compensation of cost-sharing agreements.

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