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The US Court of Appeals for the Ninth Circuit on November 12 issued an order denying Altera’s petition for rehearing en banc in the case of Altera Corp. v. Commissioner.  The order means that the Ninth Circuit will not reconsider its June 7, 2019 decision upholding the validity of Treas. Reg. sec. 1.482-7A(d)(2), requiring stock-based compensation costs to be included in the costs shared in a cost-sharing agreement. The June 7 decision is not yet final, however, because Altera may file a petition requesting the US Supreme Court to review the decision.

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