Gibson Dunn Partners Discuss Platform Contributions to Cost-Sharing Arrangements in Bloomberg Tax Article

Article  |  October 29, 2025

Bloomberg Tax

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In their article for Bloomberg Tax, partners Saul Mezei and Terrell Ussing note that “Taxpayers with cost-sharing arrangements must accept the lingering uncertainty” surrounding use of the acquisition price method “and anticipate that the IRS will continue to scrutinize platform contribution transaction payments when folding in acquisitions to existing cost-sharing arrangements.” It is particularly important for those taxpayers to prepare thoughtful transfer-pricing reports “given that the IRS has increasingly asserted penalties whenever it makes transfer-pricing adjustments,” they write.