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More Transfer Pricing Disputes And Other Altera Aftermath

Law360 (August 3, 2018, 6:50 PM EDT) -- On July 24, 2018, in Altera Corp. and Subsidiaries v. Commissioner of Internal Revenue, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a U.S. Treasury Department regulation that requires a U.S. taxpayer to allocate a portion of stock-based compensation costs to a foreign affiliate that is a participant in a cost-sharing arrangement for the development of intangible assets.[1] In the decision, the court reversed the U.S. Tax Court’s prior unanimous decision in favor of Altera, which had...
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