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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
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
Year-End Reporting For Equity Incentive Plans With UK Participants Due July 6
This alert serves as a reminder of the need for year-end reporting to the UK tax authorities with respect to options and other equity incentive awards granted to, and share acquisitions by, UK employees which occurred ...
3 Jun 2019
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
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
New York's Sleeping Economic Nexus Law Awakens
New York has had an economic nexus law on its books since 1990.
United States
6 Feb 2019
IRS Announces Adjusted Plan Limits For 2019
The amount by which the limits are adjusted each year is based on a cost of living index. Not all limits increase every year.
United States
7 Nov 2018
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
States React To Wayfair
As we previously reported, on June 21, the Supreme Court overturned the longstanding rule that a state was prohibited from requiring a remote seller to collect sales tax where the seller...
United States
16 Jul 2018
US Supreme Court Overturns Physical Presence Requirement In Sales Tax Case
The US Supreme Court handed down its decision in the closely watched case of South Dakota v. Wayfair, Inc.
United States
3 Jul 2018
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.
6 Apr 2018
Supreme Court Limits Criminal Tax Obstruction Statute
On March 21, 2018, the Supreme Court sharply curtailed the scope of conduct subject to prosecution under the criminal obstruction provision of the Internal Revenue Code.
United States
26 Mar 2018
IRS Provides Relief For Unintentional Operational Violations Of Section 409A
On December 3, 2007, the IRS issued Notice 2007-100, which provides relief for certain unintentional operational failures to comply with Section 409A.
United States
20 Dec 2007
IRS Announces Adjusted Plan Limits For 2008
The Internal Revenue Service has announced the 2008 adjusted limits that affect the operation of tax-qualified retirement plans, including 401(k) plans, and certain other types of employee benefit plans.
United States
9 Nov 2007
Halloween Treat: IRS Issues Real Transition Relief Under Section 409A
On October 22, 2007, the IRS issued Notice 2007-86 which generally provides taxpayers with an additional year in which to take advantage of certain transition rules to bring nonqualified deferred compensation plans and arrangements into compliance with Section 409A of the Internal Revenue Code and the final regulations issued thereunder.
United States
26 Oct 2007
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
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
IRS Announces Limited Compliance Program For "Rank-and-File" Discounted Stock Option Exercises In 2006
On February 8, 2007, the Internal Revenue Service issued Announcement 2007-18 announcing a compliance resolution program that permits employers to pay the additional taxes arising under Section 409A of the Internal Revenue Code due to the exercise in 2006 of certain stock options and stock appreciation rights.
United States
21 Feb 2007
Special Reporting Requirements Regarding Incentive Stock Options And Employee Stock Purchase Plans
This Alert will serve as a reminder of certain year-end reporting requirements imposed with respect to incentive stock options and employee stock purchase plans.
United States
31 Jan 2007
Diversification Rights and Notice Requirement for Retirement Plans With Investment In Employer Securities—IRS Delays Date For Providing Notice And Issues Model Notice
As we previously reported, the Pension Protection Act of 2006 (the "Act") made significant changes to the laws governing retirement plans. While the effective dates of many of these changes are staggered over the next several years, there are two related changes that are effective almost immediately, for plan years beginning on or after January 1, 2007.
United States
5 Dec 2006
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