Photo of Loretta Richard

As previously reported by Ropes & Gray, on July 24, 2018, the Ninth Circuit reversed the Tax Court’s prior decision in the Altera case and upheld the IRS regulation requiring the allocation of stock-based compensation in qualified cost-sharing agreements. The decision was particularly notable since it ended in a 2-1 vote, in which Judge Reinhardt,

In an unexpected 2-1 decision, Judge Reinhardt, who passed away in March of this past year, cast the Ninth Circuit’s deciding vote to reverse the Tax Court’s prior ruling in Altera. In 2015, the Tax Court invalidated Treasury Regulation 1.482-7A(d)(2)’s requirement that related parties allocate stock-based compensation costs when entering into cost-sharing agreements to

In a recent Tax Notes International article, “Is Fishing in Tax Waters Getting Easier or Just More High Tech?,” tax & benefits associate Brian Studniberg, former tax controversy counsel Gabby Hirz and tax controversy group co-founder and employee benefits partner Loretta Richard provide commentary on the continued role of international information exchange on request given

The Potential Threat

Class-action lawyers have set their sights on retirement savings plans offered by colleges and universities, focusing on “jumbo” plans, often with assets of more than $1 billion (though that amount may decline as the pickings become slimmer). These lawsuits are founded in claims of ERISA breaches of fiduciary duty. Colleges and universities need to understand these claims, and know what they need to do to prepare.
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