Press Room: Altera Decision

July 30, 2015

Tax Court Holds the Sec. 482 Cost Sharing Regulations Requiring Allocation of Stock-based Compensation to Non-U.S. Entity Not Valid

The Tax Court, in Altera Corporation and Subsidiaries v. Commissioner (145 T.C. 3 (2015)), has held invalid the Sec. 482 cost-sharing regulations that require controlled entities entering into qualified cost-sharing agreements (QCSAs) to share stock-based compensation ...

June 30, 2020

Supreme Court Declines to Review Ninth Circuit’s Decision in Altera to Uphold Cost-Sharing Regulations on Stock-Based Compensation

The U.S. Supreme Court has declined to issue a writ of certiorari in Altera v. Commissioner (Altera). Altera Corp.'s petition asked the Supreme Court to review the Ninth Circuit’s 2019 ...