News & Analysis as of

Equity Compensation Appeals

DarrowEverett LLP

Massachusetts Court Decision Could Spark State Tax Crackdown Nationwide

DarrowEverett LLP on

Founders and executives with equity compensation need to be prepared for state tax exposure, even in states where they do not live. In a landmark decision that reverberates beyond Massachusetts, the Massachusetts Appeals...more

Eversheds Sutherland (US) LLP

Results-disoriented–Ninth Circuit withdraws its Altera decision 

On August 7, 2018, the US Court of Appeals for the Ninth Circuit withdrew its opinion in Altera Corporation v. Commissioner, just 15 days after the initial release of the opinion. The court in Altera had overturned a Tax...more

A&O Shearman

Altera: Ninth Circuit Reverses US Tax Court and Holds that Treasury Regulation Allocating Stock-Based Compensation Expenses Is...

A&O Shearman on

On July 24, 2018, in Altera Corp. v. Commissioner, a divided panel of the U.S. Court of Appeals for the Ninth Circuit upheld the validity of a Treasury Department regulation that requires a U.S. taxpayer to allocate a portion...more

Wilson Sonsini Goodrich & Rosati

Ninth Circuit Overturns Altera and Revives Regulations on Cost Sharing of Stock-Based Compensation

On July 24, 2018, the U.S. Court of Appeals for the Ninth Circuit, in a 2-to-1 opinion, ruled in Altera Corp. v. Commissioner that Treasury Regulations involving transfer pricing promulgated in 2003 (the Regulations) complied...more

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