Tax Implications of Stock-Based Compensation and Cost-Sharing Arrangements

Course Details
- smart_display Format
Live Online with Live Q&A
- signal_cellular_alt Difficulty Level
Intermediate
- work Practice Area
Tax Law
- event Date
Tuesday, September 30, 2025
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
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BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
This CLE/CPE webinar will provide guidance to counsel and advisers on the tax issues associated with stock-based compensation and cost-sharing arrangements. The panel will discuss key elements of Section 482 and the applicable Treasury regulations, the impact of the One Big Beautiful Bill Act (OBBBA), IRS enforcement actions, and transfer pricing challenges, as well as offer best practices and pitfalls to avoid in structuring stock-based compensation and cost-sharing arrangements.
Faculty

Mr. Tanner is a Partner in Rimon’s Employment Law, Employee Benefits and Executive Compensation Practice. He has over 25 years of experience in representing US and multinational companies with executive compensation, equity compensation, employment, and data privacy matters.
Description
The complexity in structuring stock-based compensation and cost-sharing arrangements requires corporate taxpayers to adopt a tailored approach or accept substantial risk. To minimize adverse tax consequences, attorneys and advisers must recognize the tax implications when structuring and implementing stock-based compensation in cost-sharing arrangements.
Many multinational companies enter into cost-sharing agreements with their affiliates in low-tax jurisdictions. Within these arrangements, employees may be compensated with stock-based compensation, allowing the multinational company to take advantage of certain tax benefits. Now, these companies must reevaluate their tax positions and possibly restructure their cost-sharing arrangements since they may no longer be able to deduct the full cost of stock-based compensation.
In addition, the excise tax under Section 4501 applies to the repurchase of corporate stock. This excise tax applies directly to repurchasing corporations and significantly impacts stock-based compensation structures.
Listen as our panel discusses critical elements of Section 482 and applicable Treasury regulations, recent IRS enforcement actions, and transfer pricing challenges, as well as offers best practices in structuring stock-based compensation in cost-sharing arrangements and the potential application of Section 4501.
Outline
I. Section 482 and applicable regulations on stock-based compensation and cost-sharing arrangements
II. Recent IRS enforcement initiatives
III. Key considerations in structuring stock-based compensation in cost-sharing arrangements
IV. Applicability of Section 4501 excise tax
V. Impact of OBBBA
VI. Best practices and pitfalls
Benefits
The panel will review these and other crucial issues:
- What are the key tax considerations in structuring stock-based compensation and other arrangements?
- What issues arise from stock-based compensation in cost-sharing arrangements?
- Applicability of Section 4501 excise tax on stock-based compensation structures and pitfalls to avoid
- Impact of OBBBA
- What are the standards of review in the IRS examination of stock-based compensation and cost-sharing arrangements?
NASBA Details
Learning Objectives
After completing this course, you will be able to:
- Identify key issues with the application of Section 482 to stock-based compensation cost-haring arrangements
- Recognize key tax issues in structuring stock-based compensation
- Understand the bases of IRS enforcement initiatives and review standards for stock-based compensation cost-sharing arrangements
- Field of Study: Taxes
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business, legal or public firm experience at mid-level within the organization, providing tax planning and preparing complex tax forms and schedules for partnerships and LLCs; supervisory authority over other preparers/accountants. Knowledge and understanding of partnership and LLC structure, equity compensation in these entities; familiarity with equity compensation alternatives and equity interest for pass-through entity employees, members and partners.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).
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