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- Title
ALTERA CORP. V. COMMISSIONER: A RARE GOVERNMENT VICTORY IN TRANSFER PRICING.
- Authors
Brian, Seth
- Abstract
The article discusses the court case Altera Corp. v. Commissioner wherein logic devices manufacturer Altera Corp. and its subsidiary Altera International challenged the U.S. Internal Revenue Service Commissioner's enactment of Section 482 of the Internal Revenue Code on transfer pricing between related entities. It discusses the Ninth Circuit's reversal and withdrawal of opinion on the Tax court's decision on the rule's invalidity per the Administrative Procedure Act's rulemaking requirements.
- Subjects
UNITED States; TRANSFER pricing laws; ALTERA Corp.; COMMISSIONERS; UNITED States. Internal Revenue Service; INTERNAL revenue law; UNITED States. Court of Appeals (9th Circuit); ACTIONS &; defenses (Law)
- Publication
University of Cincinnati Law Review, 2018, Vol 87, Issue 4, p1
- ISSN
0009-6881
- Publication type
Article