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...

Stay ahead of the curve

In the legal profession, information is the key to success. You have to know what’s happening with clients, competitors, practice areas, and industries. Law360 provides the intelligence you need to remain an expert and beat the competition.


  • Access to case data within articles (numbers, filings, courts, nature of suit, and more.)
  • Access to attached documents such as briefs, petitions, complaints, decisions, motions, etc.
  • Create custom alerts for specific article and case topics and so much more!

TRY LAW360 FREE FOR SEVEN DAYS

Hello! I'm Law360's automated support bot.

How can I help you today?

For example, you can type:
  • I forgot my password
  • I took a free trial but didn't get a verification email
  • How do I sign up for a newsletter?
Beta
Ask a question!