What Non-US Startups Need to Know About Granting Stock Options
What Every Start Up Should Know About Stock Options
Common Equity Plan Pitfalls
Why is a 409A Valuation Important?
Early Exercise Stock Options
Nowotny on Death and Taxes Episode 6 Surfs Up Dude! High Tech Tax Solutions for High Tech Workers
Episode 26: Talking Tax Reform and Executive Comp
Private company clients frequently ask us about granting compensatory stock options to their founders, employees and other service providers, including board members, consultants and advisors. Options and other equity awards...more
This article is the second in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees?...more
Wichtiger Hinweis: Die folgenden (rechtlichen) Ausführungen dienen nur der allgemeinen Information, sind nicht abschließend und stellen keine rechtliche, steuerrechtliche oder sonstige Beratung dar. ...more
Double-vest restricted stock unit awards (Double-Vest RSUs) made headlines a few years after the end of the Great Recession when they were awarded by pre-IPO tech giants. Since that time, it has become increasingly common for...more
For (1) any exercise of an incentive stock option (ISO) during 2022 or (2) transfer during 2022 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan (ESPP), the Internal Revenue Code...more
This White Paper highlights some of the principal annual or quarterly reporting requirements for employee stock plans that multinational companies most commonly encounter when offering these programs to their employees in...more
With the holidays in full swing and less than one week remaining in 2022, we wanted to pass along a few compensation income tax related stocking stuffer reminders in connection with the year-end for which companies and/or...more
Orrick's Founder Series offers monthly top tips for UK startups on key considerations at each stage of their lifecycle, from incorporating a company through to possible exit strategies. The Series is written by members of our...more
On March 18, 2022, the Russian Central Bank clarified that the restrictions imposed under Decree No. 81 (see our earlier alert below) do not apply if a Russian resident acquires shares from a company of an “unfriendly”...more
The Russian President has issued Decree No. 81 — “due to the unfriendly actions of the US and other countries in violation of international law” — establishing special procedures for any transactions leading to the transfer...more
Before 2020, the IRS had long taken the position that an employee stock ownership plan (ESOP), and any other retirement plan for that matter, must be adopted no later than the end of the first tax year in which the employer...more
The Supreme Court of Ohio upheld the City of Cleveland’s taxation of a nonresident’s income from stock options even though the income was recognized by the nonresident seven years after the nonresident had ceased working or...more
As pandemic effects linger, companies intent on avoiding layoffs are looking at compensating workers with equity in lieu of cash as part of their pay. In August 2020, the United Kingdom began winding down its Coronavirus...more
Episode 6 is about tax planning solutions for the exercise of incentive stock options. ...more
Requirement to Report - For (1) any exercise of an incentive stock option (ISO) during 2019 or (2) transfer during 2019 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan (ESPP), the...more
This White Paper highlights some recent developments in certain countries relating to employee stock plans offered by multinational companies to employees in such jurisdictions. BELGIUM - New Tax Withholding...more
Several days ago, a precedential judgment was handed down (AA 55937-01-17, Shohat v. The State of Israel) on option plans for employees in respect of section 102 of the Income Tax Ordinance. Although the judgment considers...more
On June 17, 2019, Canada’s finance minister tabled a Notice of Ways and Means Motion regarding the taxation of employee stock options. This follows from the government’s announcement in the 2019 Budget that it intended to...more
From time to time, and primarily when the economy is booming, allowing stock options to be “early exercised” - that is, allowing options to be exercised before they are vested - becomes in vogue. We are in one of those times....more
New legislation proposed in the 2019 Federal Budget would limit the extent to which employees will be entitled to favourable Canadian income tax treatment on certain stock options....more
On December 22, 2017, the Tax Cuts and Jobs Act (the "Act") was signed into law. The Act added a new Section 83(i) to the Internal Revenue Code of 1986, as amended (the "Code"), pursuant to which certain employees of eligible...more
The Internal Revenue Service issued Notice 2018-97 on December 7, providing initial guidance for the new Section 83(i) of the Internal Revenue Code (Section 83(i)) enacted by the Tax Cuts and Jobs Act. The notice principally...more
The Internal Revenue Service issued guidance on a tax law change that permits the deferral of income tax on equity awards in private companies. Section 83(i) of the Internal Revenue Code was included in the 2017 Tax Cuts and...more
In recent years, equity compensation programs have increasingly been using restricted stock units (RSUs). A manufacturing company recently made news when it granted RSUs worth millions of dollars to thousands of its employees...more
Enterprise Management Incentive ("EMI") option plans are one of the very few UK tax advantaged option plan arrangements. Companies qualify to grant EMI options if they meet qualifying criteria, including...more