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Ninth Circuit Overturns Altera and Revives Regulations on Cost Sharing of Stock-Based Compensation

On July 24, 2018, the U.S. Court of Appeals for the Ninth Circuit, in a 2-to-1 opinion, ruled in Altera Corp. v. Commissioner that Treasury Regulations involving transfer pricing promulgated in 2003 (the Regulations) complied...more

Recent Legislation Permanently Extends Important Tax Planning Opportunity for Investors in Small Businesses

Legislation signed by President Obama on December 18, 2015, makes permanent a U.S. federal income tax exclusion from gross income of 100 percent of the gain recognized by non-corporate taxpayers on the sale or exchange of...more

Federal Budget Suspends Medical Device Excise Tax for Two Years

The Patient Protection and Affordable Care Act's (ACA) 2.3 percent medical device excise tax was contentious even before taking effect on January 1, 2013. Under the ACA, medical device manufacturers and importers are required...more

IRS Publishes Safe Harbor for Monetizing Certain Tax Credits

Following Historic Boardwalk Hall LLC v. Commissioner, 694 F.3d 425 (3d Cir. 2012), which rejected a partnership's allocation of rehabilitation tax credits to a purported partner, the Internal Revenue Service (IRS) recently...more

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