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Income Taxes › Internal Revenue Code (IRC) › Stocks

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Pillsbury - Propel

Equity Compensation: Navigating 409A Valuations

Pillsbury - Propel on

Private company clients frequently ask us about granting compensatory stock options to their founders, employees and other service providers, including board members, consultants and advisors. Options and other equity awards...more

Mayer Brown

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

Mayer Brown on

Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Rivkin Radler LLP

Withholding Taxes: Deferred Comp and Services Overseas

Rivkin Radler LLP on

Approaching Year End- Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than...more

Bilzin Sumberg

A Transition to What? SCOTUS Set to Decide the Fate of IRC 965

Bilzin Sumberg on

The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more

Orrick, Herrington & Sutcliffe LLP

Annual Reporting Requirements for Incentive Stock Options and Employee Stock Purchase Plans (UPDATED)

Orrick, Herrington & Sutcliffe LLP on

Requirement to Report - For (1) any exercise of an incentive stock option (ISO) during 2019 or (2) transfer during 2019 of a share previously purchased pursuant to a tax-qualified employee stock purchase plan (ESPP), the...more

Fenwick & West LLP

IRS Issues New Guidance on Section 83(i)

Fenwick & West LLP on

The Internal Revenue Service issued Notice 2018-97 on December 7, providing initial guidance for the new Section 83(i) of the Internal Revenue Code (Section 83(i)) enacted by the Tax Cuts and Jobs Act. The notice principally...more

Morgan Lewis

New US Tax Law Provides Tax Deferral Opportunity for Certain Private Company Equity Grants

Morgan Lewis on

The adoption of Internal Revenue Code Section 83(i) under recent US tax reform will allow certain private company employees to defer federal income tax on eligible stock options and restricted stock units for up to five years...more

Troutman Pepper

Tax Developments in 2016: Federal Tax (Part I) - Sections 355, 382, and 385; and new rules on partnership audits dominate...

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Section 385 Proposed Regulations — Impact on Related-Party Financing - Section 385 has been in the Internal Revenue Code since 1969. It was enacted to provide guidance for whether to classify an interest in a corporation...more

Proskauer - Tax Talks

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

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On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

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The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Polsinelli

Small Business Investors Can Save Big with New IRS Code Amendments

Polsinelli on

Recent amendments to the Internal Revenue Code of 1986 (the Code) have significantly expanded the opportunity for tax savings under Section 1202. Section 1202, which was originally added to the Code in 1993, provides relief...more

Wilson Sonsini Goodrich & Rosati

IRS Proposes Updates to Rules for Deemed Distributions of Stock and Stock Rights

Wilson Sonsini Goodrich & Rosati on

On April 13, 2016, the U.S. Department of the Treasury issued proposed regulations under Section 305(c) of the Internal Revenue Code that would resolve certain issues relating to the amount and timing of deemed distributions...more

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