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 ...