U.S. Supreme Court Denies Altera’s Petition for Writ of Certiorari: The U.S. Supreme Court Declines Review of Ninth Circuit Opinion Holding that Stock-Based Compensation Costs Must be Shared under Qualified Cost Sharing Agreements

Sullivan & Cromwell LLP - June 29, 2020
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On June 22, 2020, the U.S. Supreme Court denied Altera’s petition for a writ of certiorari from a Ninth Circuit’s opinion reversing a U.S. Tax Court decision.  The Ninth Circuit opinion holds that U.S. corporations must allocate to their non-U.S. affiliates a portion of the cost of stock-based compensation of employees whose work benefits the corporations’ non-U.S. affiliates pursuant to what is referred to as “qualified cost sharing arrangements”.