Let High-Profile Altera Decision Stand, Treasury Tells Court

Treasury officials are urging a U.S. appellate court to let stand a ruling on how assets shifted abroad are valued—an issue that could mean billions for multinational companies.

The document filed Aug. 29 before the U.S. Court of Appeals for the Ninth Circuit responded to Intel-owned Altera Corp.'s petition to rehear the case en banc—or before 11 of the court’s judges—on July 22.

A three-judge appellate panel ruled on June 7 that the IRS could require Altera to include the stock-option compensation of its employees in a cost-sharing arrangement used to shift intangible property to a foreign subsidiary.

The response ...