After the Supreme Court declined to review the Ninth Circuit's decision in Altera Corporation v. Commissioner, 926 F.3d 1061 (9th Cir. 2019) (cert denied ' S. Ct. ' (June 22, 2020)), the IRS has confirmed that it is examining taxpayers that did not include stock-based compensation costs as intangible development costs under Treasury Regulations ' 1.482-7A(d)(2) and 1.482-7(d)(3) (the "Regulations"). As reported in a prior post, the IRS lifted its administrative moratorium on examining such cost-sharing arrangements in the wake of...
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IRS Has Begun Examining Stock-Based Compensation Cost-Sharing Arrangements
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