Avi-Yonah, Reuven S. - 2018
On July 24, 2018, the Ninth Circuit reversed the Tax Court decision in Altera Corp. v. Commissioner, 145 T.C. 91 (July 27, 2015), which had invalidated Treas. Reg. § 1.482- 7A(d)(2). The regulation requires taxpayer to include the cost of employee stock options in the pool of costs that must be...