In Uncategorized on 04/13/2021 at 10:21

Transfer pricing geeks and Section 482 reallocators will no doubt be eagerly awaiting the stiped out decision forecasted in Altera Corporation and Subsidiaries, Docket No. 6352-12, filed 4/13/21.

For the rest of the civilized world, the Altera fight was over stock-based compensation with offshores. You’ll find the backstory in my blogposts “Sixteen Lawyers – Part Deux,” 7/27/15, “Aspirational Goals,” 7/24/16, “Cut Uncut,” 8/17/18, and “Cut Out,” 12/2/19.

That is, we’ll know the upshot unless the Genius Baristas seal the whole shebang.

I find it a wee bit unfortunate that the results of major litigations, based upon which we advisers must advise clients in big ticket matters, are kept from public view. I understand not revealing Section 6103 lockouts, discovery manœuvers, trial tactics, negotiating strategies and ploys, trade secrets, and privileged information. But stipulated decisions reveal none thereof.

Decisions are how we can judge how the whole system is working. The whole aim of tax advising is discovering if the lion will bite otherwise than by sticking one’s head in its mouth.


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