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Am I offering a taxable fringe benefit? Check the code
- Fox Rothschild LLP
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- USA
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- January 21 2013
In the fiscal cliff debates last quarter, there was some discussion about limiting deductions or changing the Tax Code to eliminate certain
Facebook founder, Mark Zuckerberg, expected to realize $6 billion in gross income on exercise of nonqualified stock options in Facebook's initial IPO
- Fox Rothschild LLP
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- USA
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- February 15 2012
Under Section 83, the transfer of property in connection with the performance of services, results in compensation to the service provider in the year in which the property received is non-forfeitable or transferable, and, if neither, if a timely election is made under Section 83(b
New technical interpretation issued by Canada Revenue Agency on stock options will spark debate
- Fox Rothschild LLP
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- Canada, USA
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- November 8 2011
A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days
Second Circuit affirms district court's decision rejecting claim for refund based on claimed overvaluation of employee stock
- Fox Rothschild LLP
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- USA
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- February 17 2011
In Gudmundsson v US, 107 AFTR 2d 107 AFTR2d 2011-456 (2nd Cir. 2011) the Court of Appeals for the Second Circuit has affirmed a district court decision which dismissed the taxpayers’ claim for refund in tax based on an alleged overvaluation of stock one of the spouse’s received under an incentive (employee) stock option plan where the stock subsequently precipitously fell in value
Year end tax planning: setting past years' peformance bonuses: deductible business expense or disguised dividend?
- Fox Rothschild LLP
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- USA
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- December 28 2009
In Menard, Inc., 560 F3d 620 (7th Cir., 2009), rev'g TC Memo 2004-207 , the Seventh Circuit Court of Appeals reversed the Tax Court and found in favor of the taxpayer that a large 5 bonus arrangement payment was in fact paid for services rendered and was deductible in computing the corporation's taxable income for 1998, the year in issue
Current Search
- Jurisdiction - USA
- Workarea - Employee Benefits & Pensions
- Firm Name - Fox Rothschild LLP
- Author - Jerald David August