Rocco Femia comments on the new transfer pricing regulations that went into effect at the start of this year, which take aim at cost sharing arrangements corporations often use to develop new intangible property and which have prompted concern about valuing existing intangible property and disclosing tax uncertainties. "The IRS says you would never have projects with new intangible property without building on old intangible property, so how do you compensate the original owner?" Femia says. "That’s really the issue being addressed by the regulation.”