Publications
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01.09.2018Impact of Tax Reform on Some Private Company Equity Awards: Limited Income Tax Deferral Opportunities for EmployeesUpdatesThe recent 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 includes a new income tax deferral regime for certain employee stock options and restricted stock units (RSUs) granted by eligible private corporations under broad-based programs that are exercised or settled after December 31, 2017.
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03.25.2010IRS Provides New Safe Harbor for Section 1031 Exchanges Using Qualified IntermediariesUpdatesThe IRS recently issued Revenue Procedure 2010-14, which provides long-awaited guidance for taxpayers whose deferred like-kind exchange of relinquished property would be non-taxable under Section 1031 of the Internal Revenue Code but for the failure of the qualified intermediary ("QI") to acquire and transfer identified replacement property due to the QI's insolvency proceedings.
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03.23.2010SGIGs Will Be Treated as Nonshareholder ContributionsUpdatesUntil recently, the taxability of Smart Grid Investment Grants (SGIGs) was an undecided issue. Effective March 10, 2010, the Internal Revenue Service (IRS) has announced that these grants will be treated as nonshareholder contributions to the capital of grant recipients and thus not included in their taxable gross income.
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12.30.2009New Requirements No Longer "Option"-al! February 1, 2010 Deadline and Final Regulations on Return and Information Statement Requirements for ISOs and ESPPsUpdatesThe Internal Revenue Service recently issued new final regulations addressing the return and information statement requirements applicable to exercises of incentive stock options, or ISOs, and transfers of shares purchased under an employee stock purchase plan, or ESPP. The IRS has waived the requirements under the new regulations for ISO exercises and transfers of ESPP shares that occur during 2009.
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03.02.2009Economic Stimulus Bill Provides First-Time Homebuyers With Expanded Tax CreditUpdatesThe American Recovery and Reinvestment Act of 2009, commonly referred to as the Stimulus Bill, was signed into law on February 17, 2009 and contains an expanded tax credit for first-time homebuyers who make qualifying purchases prior to December 1, 2009.
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02.23.2009Economic Stimulus Bill Provides Energy Tax Incentives and Relaxes Tax Rules for BusinessesUpdatesThe American Recovery and Reinvestment Act of 2009, commonly referred to as the Stimulus Bill, signed into law on February 17, 2009, contains renewable energy tax incentives, defers realization of certain cancellation of debt income, suspends certain restrictions on the deductibility of original issue discount, and limits S corporation built-in gain recognition.
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03.21.2008IRS Clarifies New Adverse Position on Section 162(m) Performance-Based Compensation Exception and Provides Transition ReliefUpdatesThe IRS recently issued Revenue Ruling 2008-13, which clarifies the IRS's new position with
respect to the applicability of the performance-based compensation exception for purposes of Section 162(m) of the Internal Revenue Code and grants transition relief to provide public companies an opportunity to review outstanding compensation plans, agreements and other arrangements in light of the IRS's new position. -
07.23.2007IRS Confirms Tax Consequences of New Vesting Restrictions on Fully Vested StockUpdates
The IRS recently issued Revenue Ruling 2007-49, which provides guidance on the tax consequences of certain transactions involving new vesting restrictions on fully vested stock. This update provides a brief background on Section 83 of the Internal Revenue Code, summarizes the key highlights from the revenue ruling and offers practical tips.
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06.07.2007IRS Narrows Definition of "Covered Employees" for Purposes of the $1 Million Limitation on Deducting Executive CompensationUpdates
This week the IRS issued guidance on identifying "covered employees" for purposes of Section 162(m) of the Internal Revenue Code in response to the SEC's recent amendments to its executive compensation disclosure rules. This Update summarizes the key highlights from this IRS guidance.
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10.22.2004President Bush Signs Bill Providing Tax Relief to U.S. Manufacturers and Temporary Tax Incentive to Reinvest Foreign Earnings in the United StatesUpdatesToday, President Bush signed the American Jobs Creation Act of 2004 (H.R. 4520) into law. The $145 billion corporate tax package contains a range of international tax reforms, corporate tax breaks and tax incentives that are intended to make United States manufacturing, service and high-technology businesses and workers more competitive and productive both in the United States and abroad.
Presentations
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02.15.2018How Have Equity Awards Been Impacted by Tax Reform?Speaking EngagementsBreakfast Briefing Series / Boise, Idaho