Loading
In Altera Corp. v. Commissioner, the U.S. Tax Court (USTC) held that a Treasury regulation requiring participants in a qualified cost sharing arrangement (QCSA) to share stock-based compensation costs (SBC) is invalid.
The Altera decision was the outcome of cross-motions for partial summary judgment...
30/09/2015 Philippe G Penelle, Deloitte Tax, US
The United States has extensive statutory, regulatory, and administrative guidance governing the conduct of transfer pricing audits. Transfer pricing audits are part of the general overall audits of large corporate taxpayers, but because of their complexity and magnitude they may become the major...
01/09/2013 Keith Reams, Deloitte, US Cindy Hustad, Deloitte Tax, US
{{article.published}}