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Stock-Based Compensation Multinationals

Orrick, Herrington & Sutcliffe LLP

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

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

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

Orrick, Herrington & Sutcliffe LLP

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

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

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