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IRS Withdraws Directive on Cost-Sharing Arrangement Stock Based Compensation

07 August 2019

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Approved Changes

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United States

On 5 August 2019, the U.S. IRS published a memorandum dated 31 July 2019 on the formal withdraw of Directive LB&I-04-0118-005. Directive LB&I-04-0118-005 was issued on 12 January 2018 and provided that examiners were to stop opening new examinations for issues related to stock-based compensation included in cost-sharing agreements until a final decision was known in relation to an appeal by Altera Corp. ({News-2019-06-11/A/5-previous coverage}). --- MEMORANDUM FOR ALL LARGE BUSINESS AND INTERNATIONAL DIVISION EMPLOYEES FROM: Douglas W. O'Donnell /s/ Douglas W. O'Donnell Commissioner, Large Business and International Division SUBJECT: Withdrawal of Directive LB&I-04-0118-005, Instructions for Examiners on Transfer Pricing...