Coming soon! Strafford will move to BARBRI Professional Education >

Tax Implications of Stock-Based Compensation and Cost-Sharing Arrangements

A live 90-minute premium CLE/CPE video webinar with interactive Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Tuesday, September 30, 2025

1:00pm-2:30pm EDT, 10:00am-11:30am PDT

Early Registration Discount Deadline, Friday, September 5, 2025

or call 1-800-926-7926
Add to your calendar

This CLE/CPE webinar will provide guidance to counsel and advisers on the tax issues associated with stock-based compensation and cost-sharing arrangements. The panel will discuss key elements of Section 482 and the applicable Treasury regulations, the impact of the One Big Beautiful Bill Act (OBBBA), IRS enforcement actions, and transfer pricing challenges, as well as offer best practices and pitfalls to avoid in structuring stock-based compensation, intercompany recharge arrangements and cost-sharing arrangements.

Description

The complexity in structuring stock-based compensation, intercompany recharge arrangements, and cost-sharing arrangements requires corporate taxpayers to adopt a tailored approach or accept substantial risk. To minimize adverse tax consequences, attorneys and advisers must recognize the tax implications, both for the parent company and subsidiary, when structuring and implementing stock-based compensation in intercompany recharge arrangements and cost-sharing arrangements.

Many multinational companies enter into intercompany recharge arrangements and cost-sharing agreements with their affiliates in low-tax jurisdictions. Within these arrangements, employees may be compensated with stock-based compensation, allowing the multinational company and subsidiary to take advantage of certain tax benefits. Now, these companies must reevaluate their tax positions and possibly restructure their cost-sharing arrangements since they may no longer be able to deduct the full cost of stock-based compensation.

In addition, the excise tax under Section 4501 applies to the repurchase of corporate stock. This excise tax applies directly to repurchasing corporations and significantly impacts stock-based compensation structures.

Listen as our panel discusses critical elements of Section 482 and applicable Treasury regulations, recent IRS enforcement actions, and transfer pricing challenges, as well as offers best practices in structuring stock-based compensation in intercompany recharge arrangements, cost-sharing arrangements and the potential application of Section 4501.

READ MORE

Outline

  1. Section 482 and applicable regulations on stock-based compensation, intercompany recharge arrangements, and cost-sharing arrangements
  2. Recent IRS enforcement initiatives
  3. Key considerations in structuring stock-based compensation in intercompany recharge arrangements and cost-sharing arrangements
  4. Applicability of Section 4501 excise tax
  5. Impact of OBBBA
  6. Best practices and pitfalls

Benefits

The panel will review these and other crucial issues:

  • What are the key tax considerations in structuring stock-based compensation and other arrangements?
  • What issues arise from stock-based compensation in intercompany recharge arrangements and cost-sharing arrangements?
  • Applicability of Section 4501 excise tax on stock-based compensation structures and pitfalls to avoid
  • Impact of OBBBA
  • What are the standards of review in the IRS examination of stock-based compensation and cost-sharing arrangements?

Faculty

Tanner, Craig
Craig Tanner
Partner
Rimon

Mr. Tanner is a Partner in Rimon’s Employment Law, Employee Benefits and Executive Compensation...  |  Read More

Attend on September 30

Early Discount (through 09/05/25)

See NASBA details.

Cannot Attend September 30?

Early Discount (through 09/05/25)

You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.

To find out which recorded format will provide the best CLE option, select your state:

CLE On-Demand Video

BARBRI | Strafford

Strafford is Now Part of BARBRI for Professionals!

The same expert-led professional development courses you know and love from Strafford are now part of BARBRI, the trusted global leader in legal education.

Please note that the Strafford website will soon be archived. All programming, account details, and certificates will soon be migrating to our new site at barbri.com/professional-development.

All customers will be notified once this migration has been completed.