IRS CCA: Change in Controlled Participants Not Material Change in Scope of a CSA (IRC §482)

The Chief Counsel’s Office advised on whether a change in one or more of the controlled participants in a cost sharing arrangement (CSA) constitutes a “material change in the scope of the CSA from its scope as of January 5, 2009" under Treas. Reg. §1.482-7(m)(3). The guidance states that the regulatory history of Treas. Reg. §1.482-7(m)(3) indicates that a change in controlled participants is not otherwise a material change in the scope of the CSA. [CCA 202538023]

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