Tax Challenges of Multinational Employment Benefits: RSUs, Stock Options, Deferred Compensation, Retirement Plans

RSUs and stock options are dissimilar benefits. RSUs offer ownership of a company when vested, while stock options provide an opportunity to purchase shares in a business. If RSUs vest while the employee lives outside the U.S., they could be taxed by the resident country. When holding and selling RSUs, owners need to consider any tax treaties between the U.S. and the resident country, the foreign tax credit, and residency status.

Even more complex is the taxation of retirement plans and pensions. Pensions can be treated as foreign grantor trusts creating PFIC issues. Earnings on non-qualified foreign plans can be subject to taxation as earned. However, treaty benefits could provide relief. International tax advisers working with taxpayers working in multiple countries need to understand how the U.S. and other countries tax employee benefits.

Listen as our panel of international experts explains tax considerations for taxpayers receiving benefits from U.S. companies and businesses outside the U.S.

1. Multinational benefits: introduction
2. RSUs and stock options
3. Pensions and retirement income
4. Deferred compensation
5. Other benefits
6. Treaty relief
7. Foreign tax credits
8. Planning opportunities

The panel will cover these and other critical issues:

• Determining whether a foreign pension plan is qualified for U.S. tax purposes
• When earnings on foreign plans may be subject to current taxation
• Potential tax consequences of vested RSUs when living abroad
• Treaty benefits available to mitigate or eliminate taxation of certain benefits

Learning Objectives

After completing this course, you will be able to:

• Identify certain non-qualified retirement plans
• Determine treaty benefits available to mitigate tax on multinational benefits
• Decide when foreign tax credits can offset double taxation of benefits
• Ascertain when RSUs are subject to taxation in the U.S.

• 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 or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of international taxation including residency determination, foreign entity classifications, application of treaty benefits, as well as GILTI, Subpart F, and the related Section 250 deductions.

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.

IRS Approved Provider

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