In The News
Positions Remain Entrenched After Government’s Altera Brief
Tax Notes
21 May 2020
Positions Remain Entrenched After Government’s Altera Brief
Edward Froelich spoke to Tax Notes about the government’s brief regarding Altera Corp.’s bid for Supreme Court review of the Ninth Circuit’s opinion on the 2003 cost-sharing regulations.
According to Edward, the government’s brief suffers from the same defect as the Ninth Circuit’s majority opinion. “It relies on Treasury’s assertion that the sharing of stock-based compensation costs is consistent with the arm’s-length standard without any support for that assertion and despite contrary evidence in the data provided to the Tax Court,” he said.
Read the full article.
Practices