The human brain is especially evolved to anticipate and calculate an action, particularly the prefrontal cortex. A covered intangible is any intangible property that is developed as a result of the research and development undertaken under the cost sharing arrangement (intangible development area); (vi) The conditions under which the arrangement may be modified or terminated and the consequences of such modification or termination, such as the interest that each participant will receive in any covered intangibles. Therefore, R + D is treated as a service provider for purposes of this section and must receive arm's length consideration for the assistance it is deemed to provide to USP and FS, under the rules of § 1.482-4(f)(3)(iii). For the treatment of lump sum payments, see § 1.482-4(f)(5) (Lump sum payments); (ii) Installment payments. Dr. Paul Hokemeyer, a Manhattan psychiatrist, suggests that learning to anticipate is a sign of maturity. (5) Conduct inconsistent with the terms of a cost sharing arrangement. Other bases for measuring anticipated benefits may, in some circumstances, be appropriate, but only to the extent that there is expected to be a reasonably identifiable relationship between the basis of measurement used and additional income generated or costs saved by the use of covered intangibles. (ii) Example. If a controlled taxpayer that is not a controlled participant (within the meaning of this paragraph (c)) provides assistance in relation to the research and development undertaken in the intangible development area, it must receive consideration from the controlled participants under the rules of § 1.482-4(f)(3)(iii) (Allocations with respect to assistance provided to the owner). (iii) (A) In the year 2002 the district director examines the cost sharing arrangement. Any payment made or received by a taxpayer pursuant to an arrangement that the district director determines not to be a qualified cost sharing arrangement, or a payment made or received pursuant to paragraph (g) of this section, will be subject to the provisions of §§ 1.482-1 and 1.482-4 through 1.482-6. Search anticipated benefits and thousands of other words in English definition and synonym dictionary from Reverso. Notwithstanding the limitations on adjustments provided in paragraph (f)(3)(iv)(B) of this section, adjustments to cost shares based on an unreliable projection also may be made solely among foreign controlled participants if the variation between actual and projected benefits has the effect of substantially reducing U.S. tax. Consent Documents. (i) A list of the arrangement's participants, and any other member of the controlled group that will benefit from the use of intangibles developed under the cost sharing arrangement; (ii) The information described in paragraphs (b)(2) and (b)(3) of this section; (iii) A description of the scope of the research and development to be undertaken, including the intangible or class of intangibles intended to be developed; (iv) A description of each participant's interest in any covered intangibles. It is therefore essential that the ownership of the realisation plan is maintained beyond project delivery through to complete realisation. The consideration for an acquisition described in this paragraph (g) may take any of the following forms: (i) Lump sum payments. The principal costs in the intangible development area are operating expenses incurred by FS in Country Z of 100X annually, and operating expenses incurred by USP in the United States also of 100X annually. 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