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Tax Refunds Available for Cost Sharing Arrangements Containing Stock Base Compensation

Tom Phalen Corporate Tax, Tax Services, Tax Strategy, Taxing Times

U.S. taxpayers that reported Cost Sharing Arrangements (CSAs) on tax returns which contain stock based compensation under IRC Section 482 should consider filing amended tax returns for prior tax years. This recommendation is based upon a July 27, 2015 Tax Court case, Altera Corp. v. Commissioner, where the court held that the tax regulations requiring stock based compensation to be …