Tag: Stock option costs

US vs Xilinx Inc, May 27, 2009, Court of Appeal

US vs Xilinx Inc, May 27, 2009, Court of Appeal

In a decision the IRS determined that Xilinx should have allocated stock option costs for foreign subsidiary research and development employees as part of its Section 482-7 cost-sharing agreement calculation. The United States Tax Court overruled the IRS, finding that in an arm’s-length situation, unrelated parties would not allocate employee stock option costs in the way determined by the IRS. The Court of Appeals later in 2009 overruled the opinion of the tax court, and found in favor of the IRS. US-vs-XILINX-INC-CIR06-74246 ... Continue to full case
US vs. Xilinex Inc, August 2005

US vs. Xilinex Inc, August 2005

In a decision the IRS found that Xilinx should have allocated stock option costs for foreign subsidiary research and development employees as part of its Section 482-7 cost-sharing agreement calculation. In this decision, the United States Tax Court overruled the IRS, finding that in an arm’s-length situation, unrelated parties would not allocate employee stock option costs in the way determined by the IRS. The US Court of Appeals later in 2009 overturned the opinion of the tax court, and found in favor of the IRS. US-Xilinx_decision_08302005 ... Continue to full case