In Notice 2011-19, "Definition of 'Readily Tradable' on an Established Security Market," the IRS has put into regulations the long-held assumption that companies are considered privately held unless their stock is readily tradable on an established security market.
The next IRS phone forum on employee plans, "Determination Letter Issues Regarding Employee Stock Ownership Plans," will take place on October 28 (11:00 AM Pacific, noon Mountain, 1:00 PM Central, 2:00 PM Eastern).
The IRS has delayed implementation of its proposal to impose payroll taxes on incentive stock option and Section 423 employee stock purchase plan exercises "indefinitely." The Treasury Department has been under increasing pressure from industry and a number of members of Congress, including a Rep
One of the most confusing and controversial aspects of the proposed rules for anti-abuse testing on S corporation ESOPs (Temporary and Proposed Treasury Regulation Section 1.409(p)-1 T) concerned the combination of the family attribution rules under existing tax law with the specific tests for fa
In Revenue Procedure 2002-50, the IRS provided an exemption from 1099-B reporting requirements for stock brokers handling the sale of shares acquired through options by employees, former employees, or other people providing a service to a company who engage in same-day sale transactions.
The IRS clarified at an American Bar Association conference that its new focus on ESOPs extends only to abusive schemes involving high-income taxpayers.
