Corporate Taxes, Cost-Sharing

IRS Resumes Examinations of Stock Based Compensation in Cost Sharing Agreements

McDermott Will & Emery on 8/9/2019

On July 31, 2019, the Internal Revenue Service (IRS) Large Business and International (LB&I) division formally withdrew its Directive (LB&I-04-0118-005) instructing examiners on transfer pricing selection related to stock...more

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

Orrick, Herrington & Sutcliffe LLP on 6/21/2019

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

Ninth Circuit Upholds Validity of Cost-Sharing Regulations that Stray from Arm's-Length Standard

Orrick, Herrington & Sutcliffe LLP on 8/3/2018

On July 24, 2018, in the Altera Corp v. Commissioner decision, the Ninth Circuit overturned a 2015 U.S. Tax Court opinion and upheld the validity of regulations requiring taxpayers to treat stock-based compensation as a cost...more

Window on Washington - Vol. 1, Issue 38

Clark Hill PLC on 12/12/2017

One Shutdown Averted, Countdown Begins Again: With the government funded through December 22, House and Senate leadership are shifting their focus on how to structure a long-term spending deal that would include an increase...more

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on 10/5/2015

Regulatory Developments Under § 367 Affecting Transfers of Appreciated Property to Foreign Corporations - Introduction: On September 14, the U.S. Department of the Treasury (Treasury) and the Internal Revenue...more

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

Pillsbury Winthrop Shaw Pittman LLP on 8/8/2015

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more