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Positions Remain Entrenched After Government’s Altera Brief

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Edward Froelich spoke to Tax Notes about the government’s brief regarding Altera Corp.’s bid for Supreme Court review of the Ninth Circuit’s opinion on the 2003 cost-sharing regulations.According to Edward, the government’s brief suffers from the same defect as the Ninth Circuit’s majority opinion. “It relies on Treasury’s assertion that the sharing of stock-based compensation costs is consistent with the arm’s-length standard without any support for that assertion and despite contrary evidence in the data provided to the Tax Court,” he said.Read the <a target="_blank" href="http:https://media2.mofo.com/v3/assets/blt5775cc69c999c255/blt35788230981d5558/6273211e4886af2aa2be1400/200519-positions-remain-entrenched.pdf">full article</a>.