News & Analysis as of

Subsidiaries Cost-Sharing

A&O Shearman

Guarantee unenforceable due to amendments to an underlying agreement: a “trap for the unwary”

A&O Shearman on

The judgment provides a helpful reminder of the distinction between guarantees and indemnities, and how they interact with a defence of equitable set-off. The court also held that pure guarantee obligations had been...more

Baker Donelson

OIG Advisory Opinion 18-07 Permits GPO Expansion to Serve Wholly Owned Members

Baker Donelson on

In Advisory Opinion No. 18-07, issued July 30, 2018, the OIG permitted a group purchasing organization (GPO) to serve health care facilities owned by the same parent organization as the GPO. While acknowledging that the...more

Eversheds Sutherland (US) LLP

Share and share alike - the Ninth Circuit upholds regulations on stock-based compensation costs in cost-sharing arrangements

On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. § 1.482-7A(d)(2), which provides that a...more

Manatt, Phelps & Phillips, LLP

Manatt on Health Reform: Weekly Highlights - April 2017 #4

The ACA reduced uninsurance among veterans by 40%; Marketplaces showed signs of stabilizing in 2016; and some states are giving insurers more time to make decisions about offering coverage on the Marketplace next year in...more

Alston & Bird

Tax Court Déjà Vu – IRS Tried, and Failed, to Overturn Veritas

Alston & Bird on

In a recent decision (Amazon Inc. v. Commissioner, March 23, 2017), the Tax Court handed the IRS an unsurprising loss when it attempted to relitigate many of the same issues it unsuccessfully raised before the Tax Court in...more

Jones Day

Amazon v. Commissioner: IRS Cost Sharing Buy-In Challenge Rejected Again

Jones Day on

On March 23, 2017, the U.S. Tax Court issued its long-awaited opinion in a transfer pricing dispute involving Amazon's cost sharing arrangement ("CSA") with its Luxembourg subsidiary... ...more

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