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


Thursday, October 29, 2020

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

Early Registration Discount Deadline, Friday, October 2, 2020

or call 1-800-926-7926

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.

Description

The U.S. Supreme Court declined to issue a writ of certiorari in Altera v. Commissioner upholding regulations requiring controlled entities entering into cost-sharing agreements to share stock-based compensation. Attorneys and advisers must recognize the tax implications to multinational companies when structuring and implementing stock-based compensation in cost-sharing arrangements.

Many multinational companies enter into 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 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.

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 cost-sharing-arrangements.

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Outline

  1. Section 482 and applicable regulations to stock-based compensation and cost-sharing arrangements
  2. Recent IRS enforcement initiatives
  3. Key considerations in structuring stock-based compensation in cost-sharing arrangements
  4. Best practices and pitfalls to avoid for counsel and employers

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 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?

Faculty

Paruthi, Sid
Sid Paruthi

Managing Director
Moss Adams

Mr. Paruthi has been providing transfer pricing consulting services since 1998. He has extensive experience helping...  |  Read More

Additional faculty
to be announced.

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Strafford will process CLE credit for one person on each recording. All formats include program handouts. To find out which recorded format will provide the best CLE option, select your state:

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