About the Course
Introduction
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), and transfer pricing challenges, as well as offer best practices and pitfalls to avoid in structuring stock-based compensation, intercompany recharge arrangements and cost-sharing arrangements.
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
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.
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.
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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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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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?
Related Courses
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Available On-Demand
