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.