Tag: Altera

Altera Deconstructed: A Nuanced Alteration in Tax Law
Tax Court’s Unanimous Opinion Deals With Unusual Regulatory Situation

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On July 27, the Tax Court issued a unanimous opinion1 in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), in which the court held that Treas. Reg. § 1.482-7(d)(2) is invalid. It is relatively rare for a court to invalidate Treasury regulations, and, for that reason alone, the decision…