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.