The Resource Double dipping : the cross-border taxation of stock options

Double dipping : the cross-border taxation of stock options

Label
Double dipping : the cross-border taxation of stock options
Title
Double dipping : the cross-border taxation of stock options
Creator
Subject
Language
eng
Summary
This article examines the international tax issues raised by global stock option plans. It first examines the financial reasons for and unique issues raised by granting employees stock options and the U.S. accounting treatment of stock option plans. It then reviews the U.S. and tax treaty rules applicable to holders and issuers of non-qualified stock options and examines the conflicts that arise when a compensatory option holder or option income is subject to the tax jurisdiction of more than one country. Finally, it considers unilateral, bilateral, and multilateral policy options of tax administrators in the face of the global stock option plans. This article argues that the United States should consider unilaterally amending its foreign tax credit regime to prevent the double taxation of option holders, incorporate option provisions in its income tax treaties, and support the general multilateral approach set forth in the OECD Report
Citation source
In: Rutgers law journal. - Camden. - Vol. 35 (Fall 2003),
http://library.link/vocab/creatorName
Colón, J.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • employee stock options
  • tax treaty
  • foreign tax credit
Label
Double dipping : the cross-border taxation of stock options
Instantiates
Publication
Label
Double dipping : the cross-border taxation of stock options
Publication

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