On May 13, 2020, the Treasury Department and the Internal Revenue Service proposed revisions to the regulations under section 162(f) of the Internal Revenue Code (the “Proposed Regulations”). Generally, section 162(f) governs...more
On June 7, 2019, in Altera Corp. v. Commissioner, a reconstituted panel of the U.S. Court of Appeals for the Ninth Circuit issued a new opinion upholding the validity of a Treasury Department regulation addressing the...more
On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more
7/31/2018
/ Administrative Procedure Act ,
Appeals ,
Chevron Deference ,
Corporate Taxes ,
Equity Compensation ,
Foreign Affiliates ,
Internal Revenue Code (IRC) ,
Reversal ,
State Farm Fire and Casualty Co v United States ex rel Rigsby ,
Tax Court ,
U.S. Treasury