The Resource Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock

Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock

Label
Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock
Title
Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock
Creator
Subject
Language
eng
Summary
Not every cross-border payment by a subsidiary involving its parent's stock is treated as a repatriation transaction that must be tested under Section 301. As discussed in this article, it is possible in certain compensation arrangements for a subsidiary to reimburse its parent for the parent's stock that the parent provides to the subsidiary's employees. Such stock is provided to the subsidiary's employees with respect to services that the employees provide to the subsidiary. In private letter rulings, the IRS has applied Reg. 1.1032-3 and concluded that a foreign subsidiary's reimbursement of its domestic parent for the parent's stock in connection with a compensation arrangement was not a repatriation transaction
Citation source
In: Journal of international taxation. - New York. - Vol. 25 (2014),
http://library.link/vocab/creatorName
Calianno, J.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • cross-border transaction
  • repatriation
  • private ruling
Label
Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock
Instantiates
Publication
Label
Cross-border stock compensation arrangements and reg. 1.1032-3 : a subsidiary's payment for its parent stock
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
Processing Feedback ...