Sullivan & Cromwell
August 3, 2010
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Xilinx & Cost Sharing of Employee Stock Options
IRS Acquiesces in Xilinx Decision but only for Pre-2003 Cases: IRS Acquiesces in the Result (but Not the Reasoning) of Ninth Circuit Holding that Employee Stock Option Expenses Need Not Be Shared Among Related Parties Under Pre-2003 US Transfer Pricing Rules
Ninth Circuit Upholds Arm's-Length Standard, Rejects Cost-Sharing of Stock-Based Compensation [Xilinx]
Cooley Godward Kronish
March 29, 2010
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Court Addresses (Again!) Employee Stock Option Expenses for Transfer Pricing Purposes: Ninth Circuit Reverses Itself and Holds that the Arm’s-Length Standard Controls in Determining if Employee Stock Option Expenses Must Be Shared Among Related Parties Under Pre-2003 US Transfer Pricing Rules [Xilinx, Inc. v. Comm’r]
Sullivan & Cromwell
March 24, 2010
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US Ninth Circuit Reverses Course in Xilinx, Rejects IRS Effort to Require Cost Sharing of Employee Stock Options
Mayer Brown
March 24, 2010
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Ninth Circuit Reverses Course in New Xilinx Opinion, Grants Significant Victory to Taxpayer
Miller Chevalier
March 23, 2010
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IRS Loses Major International Tax Case: Ninth Circuit Changes Course, Affirms Decision in Xilinx
Morgan Lewis
March 23, 2010
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Cautious Optimism as Ninth Circuit Withdraws Xilinx Decision
Morgan Lewis
January 13, 2010
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Ninth Circuit Reverses Tax Court on Including Stock Option Costs in Cost-Sharing Agreement: A Tale of Two Regulations [Xilinx, Inc. v. Commissioner]
Morrison & Foerster
June 3, 2009
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Ninth Circuit Reverses Tax Court in Xilinx, Rules IRS Administrative Position Contrary to Arm’s Length Standard
Mayer Brown
May 29, 2009
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