After discussing the issues for a tax deduction for share-based awards in Israel in my last blog, I wanted to revisit another tax deduction conundrum, this time in Canada. In the past, the Canada Revenue Agency (CRA) generally has not allowed a local tax deduction for the cost of share-settled awards (other than under very narrow circumstances). However, based on a technical interpretation released on April 12, 2017, the CRA updated its position such that…
I hope most of you have seen our client alert on the recent Israeli Supreme Court ruling that confirmed that stock-based compensation has to be included in the cost base of Israeli subsidiaries of multinational companies. As a result of the decision, we have already seen a flurry of activity as many companies are evaluating how to obtain a tax deduction for awards granted to Israeli employees. As a reminder, for companies with a cost-plus…
Background As most of you are aware, the collection, processing, use and transfer of personal data is regulated and restricted in most countries outside the US. This is especially true for countries in the EU and EEA, where any such action generally requires a valid basis, or risks being illegal. Compliance with EU data privacy requirements can be challenging for US-based multinationals which collect, process and transfer personal data of EU/EEA-based employees to administer the employees’…
If it seems that most of my blog posts are dedicated to France, then you are correct.
For this, we can blame the many changes that have been adopted to the French-qualified regime for RSUs over the last few years, most recently discussed in my post from April 2017. And, alas, another change is on the horizon.
The proposed Tax Cuts and Jobs Act includes some very concerning changes to the tax treatment of equity-based awards granted to U.S. taxpayers. Please review our alert on these changes. We will monitor the proposed bill closely so please check back frequently. Best regards, Barbara
When granting equity awards, one of the most important questions is the tax effect of such awards. Granting awards that have a negative tax impact on the employee or the company is counter-productive and should lead companies to consider other ways to incentivize their employees. On the other hand, should companies maximize the availability of favorable tax treatment for equity awards in certain countries? This is not an easy question to answer. Favorable Tax Treatment…
The Rise of Total Reward Statements Starting a few years ago, many companies embraced the use of Total Reward Statements (TRS) in which they tried to summarize all of the different compensation items paid to an employee in one statement, ostensibly to make it easier for an employee to see, at a glance, how much money they were actually making. A TRS usually includes base salary, bonus payments, commission payments and, of course, equity awards.…
There are a few countries that require special annual reports for share plan transactions (in addition to regular annual payroll reports). Australia and the UK are among these countries and are both on a fiscal year that differs from the calendar year. The UK tax year ended on April 5 and the Australian tax year will end on June 30. The UK Annual Share Plan Return (formerly known as Form 35, for tax-qualified awards, and Form…
Less than 18 months after the latest amendment to the regime for tax-qualified RSUs in France, another amendment became effective on December 30, 2016. This amendment is the third amendment to the regime in five years, meaning that companies may (in theory) have to administer tax-qualified RSUs that are subject to three different income tax and social tax regimes. The three different qualified RSU regimes are as follows: French-qualified RSUs granted after September 28, 2012…
It is almost the end of the calendar year, and in addition to wrapping up gifts and holiday parties, it is time for multinational companies to consider the necessary tax and regulatory filings for global stock plans triggered by the close of 2016. As you consider the steps your company may need to take to start the new year right, please see our Global Equity Services Year-End / Annual Equity Awards Filing Chart, which contains…