Compensatory transfers of stock to employees of subsidiary corporations - the international implications of the proposed regulations under s. 1032

Article Abstract:

IRS proposed regulations under IRC section 1032 provide some guidance regarding the tax treatment of stock or options transferred across borders by parent corporations as compensation to subsidiary corporation employees. Those regulations provide the best guidance available regarding these international transactions which are not fully addressed in sections 1032 or 83 or in other IRS guidance. Issues which may arise include stock basis, withholding, and deductions.

Tax Law, International, International aspects, Compensation and benefits, Subsidiary corporations, Subsidiaries, Stock transfer

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Predecessor employer entitled to deduction upon former employee's exercise of stock options and/or SARs

Article Abstract:

The IRS in Letter Ruling 9853038 and in two other similar rulings approved business expense deductions for employers on the occasion of former employees exercising nonqualified stock options or appreciation rights. The employment relationship at the time that options are granted controls the determination of which employer is allowed IRC section 162 and 404(a) deductions.

Corporate Tax Deductions & Exemptions, Corporate taxes, Expense deductions

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Federal income and employment taxes on equity compensation

Article Abstract:

The author discusses income and employment tax obligations related to such equity compensation types as stock options, stock appreciation rights, phantom stock, and employee stock purchase plans.

Securities, Income tax, Securities taxes

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