the phrase 'reimbursement or other expense allowance arrangement
' means an arrangement
that meets the requirements of paragraphs (d) (business connection), (e) (substantiation), and (f) (returning amounts in excess of expenses) of this section.
In co-development CLAs, no realization event occurs upon entry into the arrangement
because one cannot ascertain whether a commercially exploitable product will result, thereby making the amount of any income indeterminable with reasonable accuracy.
There is no independent verification of cost savings, quality of care indicators, or other essential aspects of the arrangement
Assets set aside (directly or indirectly) in a trust or similar arrangement
to pay NQDC are treated as property transferred in connection with the performance of services under section 83 at the time they are set aside if the assets (or the trust holding them) are located outside the United States or are later transferred outside the United States.
The sphere-packing problem, by contrast, asks what arrangement
of spheres can fit most densely into all of space.
Also, an arrangement
entered into on or before the final regulations are published that is subsequently materially modified is treated as a new arrangement
entered into on the modification date.
Specifically, the Office of Inspector General (OIG) said that the determinative factor in evaluating such arrangements
is whether the arrangement
makes sense standing on its own without any other referrals between the parties.
Under such an arrangement
, a New York broker is permitted to perform brokerage services in a foreign state even without a license.
This shared services arrangement
is implemented under a shared services contract setting forth the services, personnel, and equipment to be provided by the hospital to the subacute provider and fees charged.
Although the risk of abuse of a severance provision is obviously much more significant in the case of a voluntary termination, Treasury's view is that Congress intended to cover both voluntary and involuntary terminations, because either type could reasonably be part of a predetermined arrangement
for deferral of compensation.