US Appeals Court again overturns Altera decision, validates IRS-regulation requiring stock-based compensation costs sharing

Jun 11,2019

Altera Corporation & Subsidiaries vs. Commissioner of Internal Revenue

US Court of Appeals for the Ninth Circuit (in a second decision) again overturns US Tax Court’s invalidation of part of IRS Cost-Sharing Regulations, 2003 (Final Rule) implementing 26 U.S.C. § 482 which provides that related entities must share employee stock compensation costs in order for their cost-sharing arrangements to be classified as qua...


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