"[Chief Counsel memorandum AM2021-04] addresses two timing issues related to IRS transfer pricing adjustments of payments made among participants in a non-SBC cost sharing agreement. By its terms, the memorandum discusses such issues only in respect of agreements that include reverse claw-back provisions, but the positions and authority are much more widely applicable -- signaling that taxpayers that added reverse claw-back provisions to their agreements are in no better position than those that did not (and in fact may be worse off)."  MORE >>