Xilinx Aftermath: Potential Protective Actions for Taxpayers.
Mondaq Business Briefing › Nbr. 2005, January 2005
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Xilinx Aftermath: Potential Protective Actions for Taxpayers.
In Xilinx Inc. v Commissioner, 125 T.C. No. 4, August 30, 2005, the tax court held that the value of stock-based compensation should not be included in cost-sharing allocations under the arm's length standard of Treas. Reg. s.1.482-1. The Xilinx holding is generally limited to stock-based compensation expenses in taxable years beginning on or after January 1, 1996 through August 25, 2003 (applicable years). All stock-based compensation granted in taxable ...
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