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US Supreme Court declines to hear Altera case

22 June 2020

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Tax Alerts, National/Federal Taxation, Transfer Pricing

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United States

On 22 June 2020, the United States (US) Supreme Court announced that it was denying the petition for certiorari for Altera Corporation & Subsidiaries v. Commissioner, 926 F.3d. 1061 (2019).Altera filed the petition asking the Supreme Court to review a decision of the Ninth Circuit Court of Appeals upholding the 2003 version of Treas. Reg. Section 1.482-7 (2003 Regulations), which requires participants to include stock-based compensation costs in a cost-sharing arrangement. The denial to hear the case puts an end to the Altera’s Ninth Circuit stock-based compensation challenge.Case historyIn 2003, the Internal Revenue Service (IRS) and Treasury issued the 2003 Regulations,...