Law360 (December 20, 2019, 11:16 AM EST) -- This year's major international tax cases featured split rulings for the Internal Revenue Service in challenges by tech companies over cost-sharing within multinational groups, along with a key finding about valuing intangible assets.
In November, the Ninth Circuit declined to rehear a case in which it had ruled against chipmaker Altera, an Intel subsidiary, and affirmed an IRS regulation requiring multinational companies to share stock option expenses in joint research-and-development agreements with their affiliates.
A different three-judge panel of the appeals court handed a victory to Amazon.com in August, rejecting IRS arguments against a U.S. Tax Court finding from March 2017...
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