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Expert Analysis

How To Challenge Tax Regs On Administrative Law Grounds

Law360, New York (October 16, 2015, 3:59 PM EDT) -- In Altera Corp. et al. v. Commissioner, the U.S. Tax Court invalidated regulations under section 482 requiring participants in qualified cost-sharing agreements (CSAs) to include stock-based compensation costs in the cost pool to comply with the arm's-length standard. The discussion below summarizes the history of those regulations and focuses primarily on the court's holding and the implications of that holding with respect to administrative law issues. For a discussion of other issues related to the opinion, see Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations....

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