9th Circ. Again Revives IRS Cost-Sharing Rule In Altera Row

Law360 (June 7, 2019, 7:39 PM EDT) -- A reconstituted Ninth Circuit panel again reached a split decision to revive an IRS regulation challenged by chipmaker Altera Corp., ruling Friday that the agency was justified in requiring related business entities to include stock-based compensation in their cost-sharing agreements.

A three-judge panel of the Ninth Circuit in San Francisco revived an IRS regulation challenged by Altera Corp., in a case closely watched by major multinational companies. (Getty Images) A new 2-1 majority reached the same conclusion as the appellate court did the first time it heard the high-profile dispute: It overturned the U.S. Tax Court's invalidation of the 2003 regulation and...

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