On July 27, 2015, the U.S. Tax Court, in Altera Corp. and Subsidiaries v. Commissioner, 145 T.C. No. 3, invalidated a 2003 amendment to Treas. Reg. ยง1.482-7(d)(2) (2003 Amendment) that required controlled participants in a...more
On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more