buy-in
Romanian translation: contributie participativa
| 16:15 Oct 17, 2009 |
| English to Romanian translations [PRO] Bus/Financial - Finance (general) / business restructurings | |||||||
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|  Selected response from: Sandra & Kenneth Grossman Israel Local time: 05:38 | ||||||
Grading comment
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| Summary of answers provided | ||||
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| 4 +1 | Acord reciproc privind cheltuielile ce privesc achizitionarea unei parti majoritare a unei companii |
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| 1 | contributie participativa |
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| Summary of reference entries provided | |||
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| buy-in |
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| Cost Sharing Arrangement |
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Answers
2 hrs confidence: 
peer agreement (net): +1
peer agreement (net): +1Acord reciproc privind cheltuielile ce privesc achizitionarea unei parti majoritare a unei companii Explanation: Achizitionarea unei parti majore mai mare de 50% dintr-o companie de catre sau in numele unui grup de directori executivi proveniti din afara companiei , ce doresc sa conduca compania respectiva. Example sentence(s):
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15 hrs confidence:
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2 hrs |
| Reference: buy-in Reference information: http://www.answers.com/topic/buy-in Depinde de context; daca e vorba de titluri aceastea se re cumpara iar mai jos iti explica in ce conditii. |
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39 mins |
| Reference: Cost Sharing Arrangement Reference information: CSAs, formally prescribed by regulations effective on Jan. 1, 1996, have become an increasingly popular vehicle for global businesses to manage development and global use of intellectual property in a tax-efficient way. Conceptually, a CSA permits two or more companies to share (1) jointly in the cost of developing intellectual property and (2) proportionally in the revenue and profits resulting from exploiting it. As a practical matter, multinational corporations use CSAs to shift some of the revenue and profits resulting from the successful exploitation of intellectual property from the U.S. to foreign tax (often, low-tax) jurisdictions. The result is lower effective tax rates and higher earnings-per-share. CSAs may be used in connection with various kinds of intellectual property, including manufacturing technology, processes and know-how (whether patented or not) and marketing properties (such as trademarks and tradenames). CSAs are formally recognized by many foreign tax authorities under international guidelines published by the Organisation for Economic Co-operation and Development. A CSA will be respected in the U.S. only if it meets certain requirements. Among these, it must be pursuant to a written agreement and disclosed in a U.S. income tax return. Treasury is concerned that the aggressive use of CSAs by some taxpayers has resulted in a loss of U.S. tax revenue, particularly the undervaluation of "buy-in payments." In connection with entering into a CSA, one party (the contributor) typically contributes preexisting intellectual property to the CSA. The other party (the payer) must pay the contributor for the value of such property, via a buy-in payment. Under Regs. Sec. 1.482-7(g), the buy-in payment is determined based on the value of the pre-existing intellectual property at the CSA's inception. If the pre-existing intellectual property is still "on the laboratory bench," or at least not yet proven commercially, a relatively low value is often ascribed to the payment. If the intellectual property proves to be commercially successful, the profits shifted from the U.S. to the foreign tax jurisdiction may be quite large relative to the combined buy-in payment and cost-sharing payments. -------------------------------------------------- Note added at 14 hrs (2009-10-18 06:33:25 GMT) -------------------------------------------------- International Tax Review The IRS and Treasury issued new temporary cost sharing regulations which are generally effective beginning on January 5 2009. The new regulations retain the investor model which was the subject of much criticism when the regulations were first proposed in 2005. The new regulations drop some of the most offensive provisions of the proposed regulations, such as the requirement that buy-in payments for technology acquired after the commencement of cost sharing being made in the same form as the payment made to acquire the technology. In many cases, this would have required a cost sharing participant to make a buy-in payment for acquired technology in the form of an immediately taxable lump-sum, even when the underlying technology was acquired in a tax-free transaction. http://tinyurl.com/yl4swzg -------------------------------------------------- Note added at 14 hrs (2009-10-18 06:44:55 GMT) -------------------------------------------------- Platform and other contributions New terminologies are introduced — platform contribution and platform contribution transaction (PCT) — regarding the items meriting compensation by a controlled CSA participant (PCT Payor) that are reasonably anticipated to contribute to the CSA activity in the PCT Payor’s division of interest. Taxpayers should also note that “buy-in” transactions (now called “platform contribution transactions” or “PCTs” ) associated with significant changes (made after January 5, 2009) in the scope of a pre-existing arrangement will be evaluated under the temporary regulations for purposes of determining periodic adjustments. http://www.internationaltaxreview.com/includes/supplements/P... Cost Sharing Arrangements (“CSA”) allow a taxpayer to legally move and exploit intellectual property outside the U.S. when it’s related to products sold outside the U.S. This reduces the U.S. tax liability of a multi-national company in legal and appropriate ways…without getting into politics for purposes of this discussion. The heart of the Temporary Regulations is the valuing of “platform contribution transactions” (“PCT”) which were previously known as, the “buy-in.” This is a determination of payments required to move existing intellectual property offshore related to future research and development. The I.R.S. wants a high PCT and the taxpayer wants it low. http://tinyurl.com/yjon3lt Reference: http://www.britannica.com/bps/additionalcontent/18/27172394/... |
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