BarbriSFCourseDetails
  • videocam Live Online with Live Q&A
  • calendar_month November 7, 2025 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

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

$347.00

This course is $0 with these passes:

CLE
CPE
ALL
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Description

The complexity in structuring stock-based compensation, intercompany recharge arrangements, 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, both for the parent company and subsidiary, when structuring and implementing stock-based compensation in intercompany recharge arrangements and cost-sharing arrangements.


Many multinational companies enter into intercompany recharge arrangements and 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 and subsidiary 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, and transfer pricing challenges, as well as offers best practices in structuring stock-based compensation in intercompany recharge arrangements, cost-sharing arrangements and the potential application of Section 4501.

Presented By

Dmitriy Chelnitsky
Partner
Sheppard Mullin, LLP

Mr. Chelnitsky is a partner in the Employee Benefits and Executive Compensation Team of the Tax Practice Group in the firm's New York office and is the Team Leader of the firm's Employee Benefits and Executive Compensation Team. He advises public and private companies, executives and boards on executive compensation and employee benefits issues, with a particular emphasis on issues arising in the context of mergers, private equity-sponsored buyouts and divestitures, entity formations, acquisitions, IPOs and other corporate matters. Mr. Chelnitsky regularly advises companies, executive management teams and individual executives with the design, implementation and termination of compensation and benefit arrangements, including equity investments, executive employment and severance arrangements; consulting arrangements; retention, severance and change-in-control plans; cash and equity-based incentive programs; and nonqualified deferred compensation plans.

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Craig Tanner
Partner
Rimon, P.C.

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. 

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Steven C. Wrappe
Managing Director, Tax, National Technical Leader, Transfer Pricing Managing Director
Grant Thornton

Mr. Wrappe is Grant Thornton’s Transfer Pricing Technical Leader in its Washington National Tax Office. He is a globally recognized transfer pricing expert, with over 25 years of experience in transfer pricing planning, compliance and controversy for large multinational clients. During that time, Mr. Wrappe has been a Senior Attorney with the IRS Advance Pricing Agreement (APA) Program, a partner with a global law firm, and the transfer pricing controversy leader at Big Four Firms. His extensive transfer pricing controversy experience covers examinations, Appeals, and alternative dispute resolution, but his main focus has been APAs and the mutual agreement procedure (MAP). With experience in well over 200 APAs, Mr. Wrappe is the most experienced negotiator of transfer pricing issues at any firm. He has negotiated APAs and MAP agreements across all industries and involving over sixteen countries. Mr. Wrappe also negotiated the first coordinated Customs ruling/bilateral APA.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 90-minute webinar is accredited for 1.5 CPE credits.

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


  • Live Online


    On Demand

Date + Time

  • event

    Friday, November 7, 2025

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Section 482 and applicable regulations on stock-based compensation, intercompany recharge arrangements, and cost-sharing arrangements

II. Key considerations in structuring stock-based compensation in intercompany recharge arrangements and cost-sharing arrangements

III. Applicability of Section 4501 excise tax

IV. Impact of OBBBA

V. Best practices and pitfalls

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 intercompany recharge arrangements and 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?

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.

BARBRI 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.

IRS Approved Provider

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

BARBRI CE webinars-powered by Strafford-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .