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12 Jun 2020, 8:52 am
Thus, Altera seeks to have the U.S. [read post]
7 Aug 2018, 1:38 pm
(For my previous coverage of Altera, see here and here.) [read post]
17 Oct 2017, 4:00 am
TaxProf Blog op-ed: Altera Meets Chamber of Commerce, by Kristin Hickman (Minnesota): Last week, a Ninth Circuit panel heard oral arguments in the government’s appeal from Altera Corp. [read post]
7 Jun 2019, 12:25 pm
Read the opinion here: Altera v. [read post]
11 Jun 2020, 11:44 am
I also joined in an amicus brief to the 9th Circuit, urging that they reverse the Tax Court's uncharacteristically misguided ruling in the case.The taxpayer in Altera is seeking certiorari, and the Supreme Court will consider the petition later this month. [read post]
24 Jul 2018, 11:25 am
Read the majority opinion and dissent here: Altera Corp. v. [read post]
10 Oct 2017, 8:17 am
Altera raises an important administrative law question about what is required of Treasury for its regulations to be valid. [read post]
13 Dec 2018, 2:00 am
Calvin Johnson (Texas), Altera's Bonkers Accounting: Stock Compensation Really is a Cost, 161 Tax Notes 339 (Oct. 15, 2018): In this article, Johnson discusses Altera v. [read post]
6 Jul 2016, 11:00 am
I've previously blogged about the appalling decision by the Tax Court in Altera v. [read post]
17 Nov 2017, 4:05 am
Avi-Yonah (Michigan), Altera, the Arm’s Length Standard, and Customary International Tax Law, 38 Mich. [read post]
24 Jul 2018, 9:53 am
Tax Court in Altera v. [read post]
6 Jul 2016, 12:23 pm
Following up on my previous posts on Altera Corp. [read post]
3 Jun 2020, 4:00 am
Shay (Harvard), Pending Cert Petition in Altera: Tax Law in an Administrative Law Wrapper: Each day of the COVID crisis we see unprecedented administrative action to respond to the pandemic. [read post]
3 Oct 2018, 11:31 am
A number of law professors, headed by Susan Morse of the University of Texas Law School, have filed an amicus brief in the Altera case. [read post]
9 Jun 2019, 10:00 am
TaxProf Blog op-ed: Altera Redux, by Reuven Avi-Yonah (Michigan): On June 7, 2019, the Ninth Circuit Court of Appeals released its long awaited opinion in Altera.[1] Like its predecessor, the new panel chosen after Judge Reinhardt’s death reversed the Tax Court and held that the regulation requiring multinationals that enter... [read post]
8 Aug 2018, 4:00 am
Following up on my previous post, 9th Circuit Reverses Tax Court In Altera, Revives Cost-Sharing Regs In Major Loss For Intel, Other Tech Companies: in a surpising sequence of moves, the Ninth Circuit has named Judge Susan Graber as a replacement judge for the late Judge Stephen Reinhard, who cast... [read post]
10 Sep 2019, 10:00 am
Bloomberg Tax, Deference to Tax Court Isn’t Needed in Altera Case, Academics Say: Intel-owned Altera misrepresented how the Ninth Circuit should treat conflicting decisions between its own three-judge panel and the U.S. [read post]
24 Feb 2016, 7:37 am
Three further thoughts on the government's decision to appeal the Altera case, as discussed in my prior post:1) Even though the Tax Court's vehement 15-0 decision makes the appeal look, at least initially, like a big uphill climb, appealing it might make sense even if the government is pessimistic, rather than optimistic, about its prospects. [read post]
9 Oct 2017, 10:55 pm
I gather that Susan Morse and Steve Shay will be blogging about this, and I'll duly post links thereto.I previously discussed the Altera decision here and here. [read post]
17 Mar 2014, 7:56 pm
El Senado de Puerto Rico aprobó un proyecto de ley que altera las tasas de interés que aplican los clientes de casas de empeño que solicitan préstamos a cambio de artículos de valor. [read post]
