Jul 30,2018 | Shearman & Sterling

Altera: Ninth Circuit Reverses US Tax Court, Treas Reg Allocating Stock-Based Comp Expenses Is Valid

In Altera Corp. v. Commissioner, the US Court of Appeals for the Ninth Circuit upheld a Treasury Department regulation that requires companies to allocate a portion of stock-based compensation costs to foreign affiliates that participate in cost-sharing arrangements for the development of intangible assets. Shearman & Sterling summarize the judicial history and implications of this decision.

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