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Appeals › Transfer Pricing

Carlton Fields

Cost-Sharing Regulations Revived By Ninth Circuit

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The Ninth Circuit Court of Appeals reversed the Tax Court in Altera Corp. in the latest chapter of the dispute over the validity of cost-sharing regulations. The decision, issued on July 24, revives certain regulatory...more

Wilson Sonsini Goodrich & Rosati

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

Wilson Sonsini Goodrich & Rosati on

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

Foley & Lardner LLP

Fun with Roth IRAs: New Sixth Circuit Decision Blesses Aggressive Tax Planning

Foley & Lardner LLP on

A recent decision by the Federal Sixth Circuit Court of Appeals expands the potential for Roth IRAs to be used to protect income from corporate and shareholder level tax....more

McDermott Will & Emery

Focus on Tax Controversy - Spring 2015

McDermott Will & Emery on

In This Issue: - Fifth Circuit Ruling in BMC Software, Inc. v. Comm’r. Is Good News for Taxpayers - When Is a Second Inspection Not a Second Inspection? - Captive Insurance Litigation: Key 2014 Cases ...more

Bennett Jones LLP

Judicial Review Application Preserved in Transfer Pricing Penalty Case

Bennett Jones LLP on

A recent Federal Court of Appeal (FCA) case illustrates how contentious transfer pricing disputes can be – even one a taxpayer believed had been resolved! It also represents a rare situation in which the taxpayer’s...more

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