Intel-owned Altera Corp. received more industry backing as some of the biggest names in tech and tax urged the Ninth Circuit to review a cross-border tax case with potentially billions of dollars at stake.
In multiple briefs, the giants urged the U.S. Court of Appeals for the Ninth Circuit to hold an en banc rehearing after a panel upheld Treasury regulations affecting taxes on certain transfers within multinational companies. The companies behind the Aug. 1 briefs include Google LLC, Apple Inc., Facebook Inc., PepsiCo Inc., PwC, Deloitte Tax LLP, KPMG LLP, and the National Association of Manufacturers. Altera wants the Ninth Circuit to review the June 7 ruling that Treasury acted lawfully in requiring related parties—such as entities within a multinational company—to share the costs of stock-option compensation in qualified cost-sharing agreements. These are agreements to share the costs of developing property in exchange for sharing income generated by the property.