Altera Redux – The Ninth Circuit Once Again Holds in Favor of the IRS

Written by , and

Last week, our International Tax Group examines the Ninth Circuit repeating itself in reversing a unanimous Tax Court holding on the validity of the Treasury’s regulations under Section 482. We examine the reconstituted  panel’s significant decisions, which in many ways follow the first panel’s conclusions.

  • Altera v. Commissioner, Parts 1, 2, and now, 3
  • What is the meaning of “commensurate with income”?
  • What does this case say about previous standards under Chevron?

Read the full advisory here.