12 November 2019 BREAKING TAX NEWS | Ninth Circuit denies Altera's request for en banc rehearing Today, the Ninth Circuit Court of Appeals denied a request by the taxpayer in Altera v Commissioner for a rehearing before the full court on the issue of whether participants in a cost-sharing arrangement (CSA) must share stock-based compensation costs (SBC costs). A Ninth Circuit panel previously upheld 2003 regulations requiring CSA participants to share SBC costs. The taxpayer now has 90 days from November 12, 2019, to apply for certiorari to the U.S. Supreme Court. Document ID: 2019-9024 |