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
On July 11, 2018, the Treasury Department and the IRS published final Treasury regulations on inversion transactions (the “Final Regulations”). The Final Regulations substantially adopt the temporary Treasury regulations...more
On October 13, 2016, the US Department of the Treasury and the Internal Revenue Service released final and temporary regulations under section 385 of the Internal Revenue Code (the “Regulations”) that contain rules requiring...more
On April 4, 2016, the US Department of the Treasury and the Internal Revenue Service proposed regulations under section 385 of the Internal Revenue Code that would recharacterize certain related-party debt instruments, in...more