Altera Corp. v. CIR

  1. February 10, 2020

    Altera Asks US Justices To Hear Cost-Sharing Rules Challenge

    Intel subsidiary Altera Corp. asked the U.S. Supreme Court on Monday to take up the chipmaker's challenge to the Treasury Department's cost-sharing rules, arguing that the Ninth Circuit's decision to uphold the regulations permitted "a startling departure" from administrative law.

  2. November 12, 2019

    9th Circ. Won't Reconsider Ruling For IRS In Altera

    The Ninth Circuit declined Tuesday to rehear a case in which it ruled against Intel subsidiary Altera and upheld an IRS regulation requiring companies to share stock option expenses in joint research and development agreements with their affiliates.

  3. September 09, 2019

    9th Circ. Shouldn't Rehear Altera Case, 29 Academics Say

    Twenty-nine academics urged the Ninth Circuit not to grant full-court review of its ruling against Altera Corp., saying that despite the company's arguments, requiring inclusion of stock option expenses in cost-sharing agreements with foreign affiliates comports with the arm's-length standard.

  4. July 22, 2019

    Altera Seeks Full 9th Circ. Review Of Cost-Sharing Case

    Chipmaker Altera Corp. on Monday asked all Ninth Circuit judges to rehear a case in which a 2-1 majority found that the Internal Revenue Service was justified in requiring related business entities to include stock-based compensation in their cost-sharing agreements.

  5. June 07, 2019

    9th Circ. Again Revives IRS Cost-Sharing Rule In Altera Row

    A reconstituted Ninth Circuit panel again reached a split decision to revive an IRS regulation challenged by chipmaker Altera Corp., ruling Friday that the agency was justified in requiring related business entities to include stock-based compensation in their cost-sharing agreements.

  6. October 16, 2018

    IRS Urges 9th Circ. To Revive Cost-Sharing Rule

    The IRS asked the Ninth Circuit for a second time on Tuesday to reverse the U.S. Tax Court's invalidation of an agency rule challenged by chipmaker Altera Corp., arguing it hadn't flouted federal law in requiring businesses to include stock-based compensation in their cost-sharing agreements with related parties.

  7. August 20, 2018

    9th Circ. Sets Oral Reargument In Altera Suit For October

    The Ninth Circuit has scheduled a rehearing in Altera Corp.'s cost-sharing suit against the Internal Revenue Service for Oct. 16, which will give a replacement judge on the appellate court's three-member panel a chance to directly question counsel in the case.

  8. August 07, 2018

    9th Circ. Withdraws IRS Win In Altera Cost-Sharing Row

    In a move that struck transfer pricing specialists as eerily familiar, the Ninth Circuit on Tuesday withdrew its decision for the IRS in a case in which the agency had argued stock-based compensation costs must be shared with foreign affiliates in cost-sharing arrangements.

  9. July 24, 2018

    9th Circ. Revives IRS Cost-Sharing Rule Altera Challenged

    The Ninth Circuit on Tuesday overturned the U.S. Tax Court's invalidation of an IRS regulation challenged by chipmaker Altera Corp., saying the revenue agency was justified in requiring businesses to include stock-based compensation in their cost-sharing agreements with related parties.