In an unexpected 2-1 decision, Judge Reinhardt, who passed away in March of this past year, cast the Ninth Circuit’s deciding vote to reverse the Tax Court’s prior ruling in Altera. In 2015, the Tax Court invalidated Treasury Regulation 1.482-7A(d)(2)’s requirement that related parties allocate stock-based compensation costs when entering into cost-sharing agreements to develop intangible assets. The Tax Court’s decision in Altera centered on the IRS’s failure to support the regulation with examples of unrelated parties […]

Towards the end of 2017, a number of exciting developments unfolded in our field. In December the Russian tax authorities have published a long-awaited list of countries with which automatic exchange of information would start in 2019 for the reporting year 2018, for example, Switzerland. Importantly, with some countries, for example, Lichtenstein, Singapore and the UK, this exchange of information will start in 2018 for the reporting year 2017.

A number of further amendments to the […]