Semiconductor Company v. Commissioner of Internal Revenue

We assisted a semiconductor company, identifying and supporting a semiconductor industry expert. The IRS had ruled that the company 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 U.S. 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.