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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
IRS Notice 2006-4: Any real relief from 409A for private company stock valuations?
On December 23, 2005, the IRS issued Notice 2006-4 in an apparent attempt to assuage concerns of private companies regarding their compliance with the recent option pricing guidance under Section 409A of the Internal Revenue Code.
United States
 
12 Jan 2006
3
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
4
Private Company Stock Option Pricing In The 409A Era
We expect recently-issued proposed regulations under Section 409A of the Internal Revenue Code, along with recent changes in financial accounting rules and practices, to significantly and immediately affect the way in which private companies set the exercise prices for their stock options and values for other stock-based compensation.
United States
 
2 Nov 2005
5
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
6
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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