Altera Could Bolster State Transfer Pricing Scrutiny

Law360 (July 2, 2020, 10:44 AM EDT) -- On June 22, the U.S. Supreme Court denied Altera Corp.'s petition for certiorari seeking review of the U.S. Court of Appeals for the Ninth Circuit's decision upholding the U.S. Department of the Treasury's transfer pricing regulation requiring related participants in cost-sharing agreements to include stock-based compensation costs in the joint cost pool to comply with the arm's-length standard.[1]

The split Ninth Circuit court had previously reversed a unanimous, en banc decision of the Tax Court invalidating those regulations on the grounds that they violated the Administrative Procedure Act.[2]

In finding that the cost-sharing regulations adequately comported with the arm's-length standard, the...

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