Category: Altera

Tax Court Decision in Altera Overturns Important Transfer Pricing Regulations

On July 27, 2015, the U.S. Tax Court issued a stunning rebuke to the IRS by invalidating the part of the Internal Revenue Services’ (IRS) cost-sharing regulations under section 482 of the Internal Revenue Code that says taxpayers have to take into account, among other costs, the costs of stock-based… – Continue reading

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies, the tax implications are complex and sometimes baffling. A new Tax Court case has just given… – Continue reading