Tax Issues in Stock-Based Compensation: Restructuring Cost-Sharing Arrangements, IRS Enforcement Actions
A live 90-minute premium CLE/CPE webinar with interactive Q&A
This CLE/CPE webinar will provide guidance to counsel and advisers on the tax issues associated with stock-based compensation and cost-sharing arrangements in light of the U.S. Supreme Court's denial of certiorari in Altera v. Commissioner. The panel will discuss key elements of Section 482 and the applicable Treasury regulations, recent IRS enforcement actions, and transfer pricing challenges, as well as offer best practices and pitfalls to avoid in structuring stock-based compensation cost-sharing-arrangements.
- Section 482 and applicable regulations to stock-based compensation and cost-sharing arrangements
- Recent IRS enforcement initiatives
- Key considerations in structuring stock-based compensation in cost-sharing arrangements
- Best practices and pitfalls to avoid for counsel and employers
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 cost-sharing arrangements?
- What is the impact of the Supreme Court's denial of certiorari in Altera v. Commissioner on multinational companies?
- What are the standards of review in the IRS examination of stock-based compensation cost-sharing arrangements?
Mr. Paruthi has been providing transfer pricing consulting services since 1998. He has extensive experience helping... | Read More
Mr. Paruthi has been providing transfer pricing consulting services since 1998. He has extensive experience helping companies evaluate their transfer pricing strategies, preparing economic valuation modeling, and providing support for planning and compliance with local transfer pricing rules. Mr. Paruthi has a thorough understanding of transactions, including intangible property migration; buy-ins, cost-sharing, and transfers of tangible goods; services and royalties; advance pricing agreement (APA); and competent authority matters. He has experience with companies in a wide variety of industries including technology (hardware and software), consumer electronics, life sciences, and manufacturing and distribution.Close
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