U.S. Supreme Court,
Tax,
Corporate
Mar. 3, 2020
Supreme Court petition raises important questions of agency authority
Altera Corporation, a subsidiary of Intel and a leading manufacturer of programmable logic devices, recently petitioned the U.S. Supreme Court to review the unfavorable 9th Circuit decision that required the costs of stock-based compensation to be shared with an affiliate under a cost sharing agreement.
Edward L. Froelich
Of Counsel
Morrison & Foerster LLP
Email: efroelich@mofo.com
Edward represents clients in audit and litigation and is the lead of the firm's Federal tax controversy group.
Bernie J. Pistillo
Partner
Morrison & Foerster LLP
Email: bpistillo@mofo.com
Bernie is a partner in the San Francisco office of the firm's Federal Tax Group.
Altera Corporation, a subsidiary of Intel and a leading manufacturer of programmable logic devices, recently petitioned the U.S. Supreme Court to review the unfavorable decision of the 9th U.S. Circuit Court of Appeals that required the costs of stock-based compensation to be shared with an affiliate under a cost sharing agreement. This is the culmination of a long-running dispute with the Internal Revenue Service regarding the validity of a regulation imposing this r...
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