On June 7, the U.S. Court of Appeals for the Ninth Circuit released its long-awaited opinion in Altera Corp. v. Commissioner. Like its predecessor, the new panel chosen after Judge Stephen Reinhardt's death reversed the U.S. Tax Court and held that the regulation requiring multinationals that enter into a qualified cost-sharing agreement, or QCSA, to share the cost of employee stock options is valid.
Avi-Yonah, Reuven S. "9th Circ. Got Cost-Sharing Right in Altera v. Commissioner." Law360 (2019).