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Searching Content indexed under Income Tax by Cooley LLP ordered by Published Date Descending.
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Treasury Department Issues Proposed Rules On Cloud Transactions, Other Digital Content
On August 9, the US Department of the Treasury released proposed regulations on the federal income tax treatment of "cloud transactions"
United States
28 Aug 2019
2
Consider Locating Your Startup In An "Opportunity Zone"
In 2017, Congress created the Opportunity Zone program to encourage investment in economically distressed parts of the United States.
United States
18 Jul 2019
3
What Is Qualified Small Business Stock And Why Does It Matter For You And Your Startup?
If a holder sells QSBS before five years, such holder may be able to avoid tax by investing the proceeds from the sale into other QSBS.
United States
2 May 2019
4
Early Exercisable Stock Options: What You Need To Know
Upon early exercise, the optionholder receives common stock that is subject to the same vesting schedule that applied to the stock option.
United States
28 Mar 2019
5
IRS Issues Guidance On Amended Section 162(m) Rules
On Tuesday, the IRS issued widely-anticipated guidance regarding certain amendments that were made by the Tax Cuts and Jobs Act to Section 162(m) of the Internal Revenue Code.
United States
30 Aug 2018
6
Temporary Halt On Grant Of EMI Options To UK Employees
The tax advantages of EMI options are dependent on EU State Aid approval and, despite the efforts of the UK government, this approval will expire on Friday, 6 April 2018.
UK
6 Apr 2018
7
IRS Issues Additional (But Limited) Transition Relief Under 409A
On September 10, 2007, the IRS issued Notice 2007-78, which permits taxpayers to bring nonqualified deferred compensation plans into documentary compliance with Section 409A of the Internal Revenue Code and the final regulations issued thereunder.
United States
28 Sep 2007
8
Finally… Final 409A Regulations
On April 10, 2007, the Department of Treasury and the IRS issued final regulations under Code Section 409A. As discussed in our prior Cooley Alerts, Section 409A covers a wide range of nonqualified deferred compensation plans and arrangements (including stock option grants and separation arrangements).
United States
10 May 2007
9
Stock Option Backdating: the Latest “Hot Issue”
In November 2005, a publicly-traded company announced the resignation of three of its top executive officers following an SEC investigation into the backdating of stock option grants. Since then, more than 20 companies have announced the formation of independent committees to investigate option granting practices or the existence of a government investigation into their option grants.
United States
6 Jun 2006
10
Special Reporting Requirements Regarding Incentive Stock Options and Employee Stock Purchase Plans
Under Section 6039(a) of the Internal Revenue Code of 1986, as amended (the "Code"), every corporation that in 2005 issued stock upon the exercise of an incentive stock option (meaning a stock option that qualifies for the favorable tax treatment available under Section 421 of the Code) must furnish to the employee exercising the option, on or before January 31, 2006, a written statement containing certain specified information.
United States
 
12 Jan 2006
11
Nonqualified Deferred Compensation Plans in the Section 409A Era
Recently-issued proposed regulations under Section 409A of the Internal Revenue Code provide guidance relating to the operational and documentary compliance requirements for nonqualified deferred compensation plans. This Alert summarizes the rules in the proposed regulations applicable to nonqualified deferred compensation plans, which are typically provided for the benefit of a select group of key employees as "top hat" plans.
United States
15 Dec 2005
12
409A: What You Do (and Don’t) Need to Consider Before Year-end
In the last few weeks of the year, employers may wish to review their compensation arrangements (including traditional nonqualified deferred compensation plans, discounted stock options and other covered arrangements) that are subject to Section 409A of the Internal Revenue Code to determine whether any last-minute compliance is required.
United States
15 Dec 2005
13
Pricing Public Company Stock Options And SARs In The 409A Era
Recently-issued proposed regulations under Section 409A of the Internal Revenue Code provide some guidance and flexibility for public companies in setting the exercise prices for their stock options, base prices for stock appreciation rights ("SARs"), and values for other stock-based compensation.
United States
 
25 Oct 2005
14
IRS Issues Proposed Regulations Relating to Deferred Compensation
Yesterday, the IRS issued proposed regulations under Code §409A. As discussed in our prior Cooley Alerts, §409A covers a wide range of nonqualified deferred compensation plans and arrangements and imposes a number of strict requirements that such plans and arrangements must satisfy in order for participants to avoid immediate taxation, an additional 20% tax, and interest on underpayments of tax.
United States
 
6 Oct 2005
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