News & Analysis as of

Administrative Procedure Act Transfer Pricing

Sullivan & Worcester

A Warm Welcome to the Tax Trotter

Sullivan & Worcester on

Happy New Year and welcome to the Tax Trotter! What a year 2020 has been! Stock markets running high, travel low, Zoom reigning supreme with the blue light eyeglass filter becoming as popular as the anti-glare...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit Withdraws Controversial Altera Opinion And Will Allow New Judge To Make Ultimate Determination

On August 7, 2018, the Ninth Circuit withdrew its July 24 decision in Altera so that new panel member, Judge Susan P. Graber, can now consider the case....more

Carlton Fields

Cost-Sharing Regulations Revived By Ninth Circuit

Carlton Fields on

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

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

McDermott Will & Emery

Focus on Tax Strategies & Developments - October 2015

McDermott Will & Emery on

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

McDermott Will & Emery

Focus on Tax Controversy - December 2013

McDermott Will & Emery on

In This Issue: A Decade of Lessons Learned from State Tax False Claims Act Cases; Second Circuit Reaffirms Taxpayer’s Use of Protective Refund Claims; and Challenging Regulations After Mayo and Home Concrete. ...more

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