IPB Tax Insider
August 8, 2019 www.ipbtax.com

With Altera Appeal Still Pending, IRS Signals Intent to Re-Open Audits of Cost-Sharing Issue


U.S. companies that entered into qualified cost-sharing arrangements (CSAs) with foreign affiliates may soon find themselves in the audit hot seat, as the IRS has officially re-opened the door to examinations of stock-based compensation in CSA structures. The decision, announced in a memo to IRS Large Business & International Division employees that was posted to the IRS website this week, stems from the June decision by the United States Court of Appeals for the Ninth Circuit upholding the validity of the relevant regulations in Altera Corp. v. Commissioner.


1717 K Street, NW Washington, DC  T:202.393.7600