This amicus curiae brief in Altera Corporation v. Commissioner supports the government's position and the view of the majority in a 9th Circuit opinion issued on July 24, 2018 and later withdrawn. Amici are tax law professors who conclude that the stock-based compensation cost sharing...

Amici file this brief to provide the Ninth Circuit with relevant background information on the basics of transfer pricing and cost-sharing agreements, and to advance four key points. First, the 2003 cost-sharing regulation at issue in this case is substantively reasonable under the...