Podcast: Discussing and Demystifying the IRS News Release on ESOPs
Investment Management Update – Exit Strategies
Berman v. Comm’r, released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more
Employee stock ownership plan - A versatile business exit and estate planning tool - If you own a closely held business, a significant portion of your wealth may be tied up in it. So, to prepare for retirement and...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
The “Great Resignation” of 2021 and the low unemployment rates in the first half of 2022 have caused businesses to increase their focus on employee retention. What options do companies have to attract and retain employees in...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
For over 20 years, Congress has provided powerful incentives for S corporations to sponsor employee stock ownership plans (“ESOPs”) through the tax code provisions that exempt all of the income of a 100% ESOP-owned S...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
This White Paper highlights some of the principal annual reporting requirements for employee stock plans that multinational companies most commonly encounter when offering these programs to their employees in selected...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
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
Even though stock options are a commonly used compensation tool, certain issues, such as whether you must/should limit their terms and, if you do, whether you can make changes to their terms after they have been granted,...more
This client alert is intended to remind you of certain 2017 year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code), with respect to stock issued to employees or former...more
As discussed in our December 16, 2010 blog article, the IRS issued final regulations in 2009 under Section 6039 of the Internal Revenue Code (the “Code”) that require Employers to annually furnish each employee who exercised...more
Annual Information Statements and IRS Returns - Requirement to Report - For any exercise of an incentive stock option (ISO) or transfer of a share previously purchased pursuant to a tax-qualified employee stock...more