United States

Assessing the Validity of Regulations after Altera v. Commissioner

Tuesday April 12, 2016 2:00 PM - 3:00 PM EDT
From KPMG TaxWatch

KPMG TaxWatch


Event Overview

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The Altera Corp. v. Commissioner decision last year overturned the portion of IRC Section 482 regulations requiring related-party participants in a cost sharing arrangement (CSA) to share stock-based compensation costs. In addition to the potential impact on transfer pricing for taxpayers with CSAs, the U.S. Tax Court decision also calls into question how tax regulations are developed and issued in the future.

During this one-hour Webcast, KPMG professionals will discuss  the potential impact of Altera Corp. on taxpayers’ ability to challenge IRS regulations. The Webcast will cover:

  • The history of the disputes under the CSA regulations concerning stock-based compensation costs
  • The recent Supreme Court decisions concerning the validity of income tax regulations
  • The Tax Court’s decision in Altera Corp. 
  • The possible broader implications of Altera under the transfer pricing regulations and beyond. 


Thomas Zollo

International Tax Principal, Washington National Tax, KPMG LLP

Victoria Sherlock

Managing Director, Tax Controversy Services, KPMG LLP

Sharon Katz-Pearlman

Principal in Charge, Tax Controversy Services and Tax Dispute Resolution Services, KPMG LLP (U.S.)

William H. Quealy, Jr.

Director, Tax Controversy Services, KPMG LLP