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Text of IRS Notice 2005-99: Valuation of Stock-Based Compensation Under Cost Sharing Arrangements (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] Dec. 9, 2005
Excerpt: Treas. Reg. § 1.482-7(d)(2)(iii)(B) provides an elective method of measurement and timing that is applicable for taking certain options on publicly traded stock into account as intangible development costs of a controlled participant in a qualified cost sharing arrangement (QCSA). This notice extends that elective method to certain stock-based compensation commonly referred to as 'restricted shares' or 'restricted share units.'
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