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Altera Corporation Files Answering Brief In Commissioner's Ninth Circuit Appeal Of Altera
In Altera Corp v Commissioner, 145 TC No. 3, the Tax Court, in a unanimous reviewed opinion, held that regulations under Section 482 requiring parties to a QCSA to include stock-based compensation...
United States
21 Sep 2016
2
Law School Professors File Amicus Briefs In Support Of Commissioner's Position In Altera
One group of six professors first notes its agreement with the arguments advanced by the government in its opening brief.
United States
5 Aug 2016
3
Altera: Tax Court Invalidates Section 482 Regulation On Administrative Law Grounds
In Altera, the U.S. Tax Court invalidated regulations under Section 482 requiring participants in qualified cost-sharing agreements to include stock-based compensation costs in the cost pool to comply with the arm's-length standard.
United States
20 Aug 2015
4
The 3M Case: Can The IRS Overrule The Supreme Court?
In March 2013, 3M filed a petition with the U.S. Tax Court challenging the Internal Revenue Service's determination that $23.6 million in additional royalty income should be allocated to 3M's U.S. headquarters from its Brazilian subsidiary.
United States
27 Sep 2013
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