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Internal Revenue Service Stock Appreciation Rights

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Troutman Pepper

New Planning Opportunities Inspired by IRS Memo on Taxation of Equity Awards

Troutman Pepper on

Synopsis - The Internal Revenue Service (IRS) released a Generic Legal Advice Memorandum, GLAM 2020-004 (the IRS Memo) dated May 18, 2020 addressing the timing of income and payroll tax withholding on three types of employee...more

Kilpatrick

IRS Addresses the Timing of Employment Tax Deposits for Various Stock Awards

Kilpatrick on

On May 22, 2020, the IRS released an Office of Chief Counsel Memorandum (the Memo) that addresses (i) when income inclusion and the withholding of FICA and federal income taxes apply to stock-settled awards and (ii) the...more

BCLP

Good News! New 409A Regulations (Yes, Really!) – Part 2: Taking (and Giving) Stock

BCLP on

On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more

McGuireWoods LLP

IRS Provides Limited Section 162(m) Transition Relief for RSUs and Similar Equity-Based Awards

McGuireWoods LLP on

The Internal Revenue Service (IRS) recently issued final regulations under Section 162(m) of the Internal Revenue Code (Code). The final regulations are substantially similar to the proposed regulations issued by the IRS in...more

McDermott Will & Emery

Section 162(m) Final Regulations Clarify Requirements for Exemptions to $1 Million Deduction Limitation

Section 162(m) generally limits to $1 million the amount that a public company can annually deduct with respect to remuneration paid to certain covered employees. This deduction limitation, however, does not apply to...more

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