Discount Stock Options As Deferred Compensation

Recent legislation has heralded a dramatic shift in the United States federal income tax treatment of nonqualified deferred compensation arrangements. One of the potentially more far-reaching aspects of the legislation is its effect on individuals who receive certain non-statutory stock options for their services. This article focuses on the circumstances under which the Act treats compensatory stock op-tions as nonqualified deferred compensation for federal income tax purposes, the consequences of such treatment, and the resulting practical considerations in dealing with the treatment of certain stock options as nonqualified deferred compensation.

27 minute readOctober 31, 2005 at 07:21 AM
By
Kenneth B. Tillou
Matthew B. Tenney
Discount Stock Options As Deferred Compensation

Recent legislation has heralded a dramatic shift in the United States federal income tax treatment of nonqualified deferred compensation arrangements. One of the potentially more far-reaching aspects of the legislation

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