Xilinx, Inc. v. Commissioner
Court of Appeals for the Ninth Circuit
1Opinion of the Court
FISHER, Circuit Judge:
On this appeal from the tax court, we must decide whether, under the tax regulations in effect during tax years 1997, 1998 and 1999, related companies engaged in a joint venture to develop intangible property must include the value of certain stock option compensation one participant gives to its employees in the pool of costs to be shared under a cost sharing agreement, even when companies operating at arm’s length would not do so. The tax court found related companies are not required to share such costs and ruled that the Commissioner of Internal Revenue’s attempt to…
Also in this document: Dissent.
2Cases cited16 opinions
- United States v. Mead Corp.Supreme Court of the United States · 2001
- Bowen v. Georgetown University HospitalSupreme Court of the United States · 1988
- Medellin v. TexasSupreme Court of the United States · 2008
- Chickasaw Nation v. United StatesSupreme Court of the United States · 2001
- Sumitomo Shoji America, Inc. v. AvaglianoSupreme Court of the United States · 1982
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3Cited by6 opinions
- JPMorgan Chase Bank, N.A. v. KB HomeDistrict Court, D. Nevada · 2009
- Altera Corp. v. Comm'rUnited States Tax Court · 2015
- Altera Corp. v. CirCourt of Appeals for the Ninth Circuit · 2018
- Xilinx, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
- Xilinx, Inc. v. CommissionerCourt of Appeals for the Ninth Circuit · 2010
1 more not listed; retrieve them via the Exa API.