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Tax Deductions Stock Options

Mintz - Tax Viewpoints

Canada’s Federal Budget 2024: More Changes to the Stock Option Rules = More Headaches for Employers

Mintz - Tax Viewpoints on

Much of the talk about Canada’s federal budget released on April 16, 2024 (“Budget 2024”) has been concentrated on the increase to the capital gains inclusion rate, highlighted by criticism from the business community that...more

Morgan Lewis - ML Benefits

Reminder: No Need to Adopt Retirement Plans, ESOPs included, by End of 2021 for Tax Deduction Purposes

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

Amundsen Davis LLC

IRS Issues Final Section 162(m) Regulations On Companies’ Ability To Deduct Executive Pay

Amundsen Davis LLC on

The Internal Revenue Service (IRS) recently published final regulations implementing changes made by the Tax Cuts and Jobs Act of 2017 (TCJA) to Section 162(m) of the Internal Revenue Code (Section 162(m)) expanding the scope...more

Blake, Cassels & Graydon LLP

Proposed Changes to Stock Option Tax Rules

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

Orrick, Herrington & Sutcliffe LLP

Tax Act Hit to U.S. Taxpayers with Equity Ownership (Even Indirect Minority Ownership) in Foreign Entities with Unremitted...

On December 15, 2017, Congress released its final version of tax reform – the Conference Report Bill (the Bill). The Bill was signed into law by President Trump on December 22, 2017....more

Perkins Coie

Tax Cuts and Jobs Act of 2017: Year-End Planning for Businesses

Perkins Coie on

The tax reform bill, commonly referred to as the Tax Cuts and Jobs Act of 2017 (the Act), was signed into law on December 22, 2017. The Act contains a number of provisions that create significant year-end planning...more

Sheppard Mullin Richter & Hampton LLP

The President Receives an Early Christmas Present: Congress Approves Landmark Tax Bill – What Will this Mean for Executive...

On Friday, December 15, 2017, Congress put forth a final version of the Tax Cuts and Jobs Act, which would signify the largest piece of tax legislation in over thirty years if signed into law. Early in the morning on December...more

Troutman Pepper

Tax Reform Bill Tightens $1M Limit on Deductibility of Public Company Executive Compensation

Troutman Pepper on

The Tax Cuts and Jobs Act (TCJA) will make major changes to the $1 million limit on deductible compensation contained in Section 162(m) of the Internal Revenue Code....more

Wilson Sonsini Goodrich & Rosati

Proposed Tax Reform Bills of Senate and House Now Aligned on Key Compensation and Benefits-Related Tax Provisions

This WSGR Alert provides a high-level comparison of the latest tax reform proposals from the U.S. House of Representatives and the U.S. Senate as they relate to compensation and benefits matters....more

Sheppard Mullin Richter & Hampton LLP

Startups Have Much To Be Thankful For – Senate Amendments to New Tax Bill Remove Deferred Compensation and Stock Options from...

As discussed in our November 14, 2017 blog post, Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock Options, the evolution of the Tax Cuts and Jobs...more

Fenwick & West LLP

Revised Senate Tax Reform Bill Represents Win for Technology Sector

Fenwick & West LLP on

Paving the way for a net-win for technology companies, Senate Finance Committee Chairman Orrin Hatch (R-Utah) released a modified chairman’s mark to the Tax Cuts and Jobs Act that brings treatment of equity and...more

Ballard Spahr LLP

Federal Tax Reform: The Current State of Play & The Big Picture (Updated 11/16)

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Ballard Spahr LLP

Federal Tax Reform: The Senate Bill – Comparison to the House Bill, and Evaluating the Bigger Picture

Ballard Spahr LLP on

The Senate Finance Committee released a detailed description of the Senate's tax reform bill, titled the Tax Cuts and Jobs Act, on November 9. The Committee has not released the text of the bill, and likely will not do so...more

Sheppard Mullin Richter & Hampton LLP

Thanksgiving Tax Frenzy – New Tax Bill Proposes Executive Compensation Changes That Could Derail Deferred Compensation and Stock...

Congress has been in a frenzy to try and get new tax legislation passed by Thanksgiving, and members of the House and Senate would presumably rather be enjoying a feast rather than drafting and analyzing additional tax...more

Orrick, Herrington & Sutcliffe LLP

Executive Compensation Legislative Whiplash

As we reported last week, the tax reform bill released by House Republicans (the "House Bill") would eliminate deferred compensation and stock options, and then on Tuesday, November 7, the House Bill was amended to restore...more

Akin Gump Strauss Hauer & Feld LLP

Tax Cuts and Jobs Act

On November 2, 2017, the Committee on Ways and Means of the U.S. House of Representatives released its tax reform bill titled the Tax Cuts and Jobs Act (the “House Bill”). On November 6, 2017, Kevin Brady, Chairman of the...more

Dechert LLP

House Tax Reform Bill Released: Would Cause Major Changes to US Tax System

Dechert LLP on

The U.S. House of Representatives GOP conference released its long-awaited tax reform bill, the Tax Cuts and Jobs Act (the “House Bill”), on Thursday, November 2, 2017. ...more

Akerman LLP

Episode 26: Talking Tax Reform and Executive Comp

Akerman LLP on

Don’t let the episode title scare you away! Matt welcomes colleague Leanne Reagan to discuss how the House’s proposed tax reform bill impacts compensation arrangements and how, if passed into law, it could completely...more

Orrick, Herrington & Sutcliffe LLP

How The Tax Cuts And Jobs Act Will Radically Alter Executive Compensation

On November 2, 2017, House Republicans released their much anticipated tax reform proposal, entitled the Tax Cuts and Jobs Act (the "Act"). If enacted, the Act would have a significant impact on the taxation of executive...more

Jackson Walker

Case Note: Crime Doesn’t Pay and Taxes are Still Due

Jackson Walker on

In a case involving criminal forfeiture of stock option profits, the Court of Appeals for the Federal Circuit has held that no deduction is allowed for $44 million in forfeited stock option gains on which tax was previously...more

Pillsbury Winthrop Shaw Pittman LLP

Tax Court: Stock based Compensation Costs Need not be Included in International Cost-Sharing Arrangements

The Stunning Altera Case - Employee stock options are an important part of compensation—both as income to the executives and as a deduction for the employer. But when stock options are used by multinational companies,...more

Orrick, Herrington & Sutcliffe LLP

Practical Advice for Compliance with Recent Amendments to the Internal Revenue Code Section 162(m) Regulations

The recent amendments to the Section 162(m) regulations largely follow the changes set forth in the proposed regulations issued in 2011, clarifying two exceptions from the Section 162(m) tax deductibility limit...more

Troutman Pepper

New Regulations Provide Advantageous Acquisition Structures

Troutman Pepper on

New regulations issued by Treasury under Section 336(e) permit certain stock acquisitions to be treated as asset purchases, allowing buyers access to stepped-up asset basis and corresponding depreciation and amortization...more

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