Deadlines for Australian Share Plan Reports for the Australian tax year ending June 30, 2025 are approaching: Do I need to comply with the ESS reporting requirements? You will be required to comply with the ESS reporting requirements if an ESS deferred taxing point (assuming the award qualified for tax deferral at the time of grant) has happened during the Australian tax year (i.e., between July 1, 2024 to June 30, 2025). Generally, the ESS…
On the heels of the January 31, 2025 announcement from the Minister of Finance to defer the effective date of the increase to the capital gains/stock option inclusion rate (from 50% to 66.67%) to January 1, 2026, new Prime Minister Mark Carney announced on March 21, 2025 that the liberals would not pursue the legislative change, which effectively means that the capital gains/stock option inclusion rate will remain at its original 50% rate for the foreseeable future. …
Latest Developments On January 31, 2025, the Canadian Minister of Finance and Intergovernmental Affairs announced a deferral of the entry into force of amendments to the capital gains inclusion rate increase (directly impacting stock option income inclusions). Originally set to take effect on June 25, 2024, the new effective date is now January 1, 2026. This announcement provides clarity on the administration of income tax withholdings on stock option income subject to the preferential regime…
On January 14, 2025, the Internal Revenue Service (âIRSâ) published proposed regulations (the âProposed Regulationsâ) under Section 162(m) of the Internal Revenue Code (âCodeâ), which generally limits publicly held companies to a $1 million annual tax deduction for compensation paid to âcovered employeesâ in a taxable year. The Proposed Regulations implement amendments made to Code Section 162(m) by the American Rescue Plan Act of 2021 (the âARPAâ) to expand the definition of âcovered employeeâ to…
The wildfires in Los Angeles County have wreaked devastation in the area, with thousands of homes and other structures, vehicles, and more destroyed by the worst wildfire in L.A. history. In response, on January 8, 2025, President Biden approved a Major Disaster declaration for California, allowing impacted communities and survivors to immediately access funds and resources to jumpstart their recovery. As it stands, impacted individuals are in need of funds, housing, food, clothing, medical care,…
It is almost the end of the calendar year and time for multinational companies to consider the necessary tax and regulatory filings for global share plans triggered by the close of 2024 (or by the end of a local tax year or company fiscal year different from the CY).As you consider the steps your company may need to take to start the new year right, please see our Annual Equity Awards Filing Chart, which describes key employee share plan filing and…
News headlines reinforce what every business knows â that there are business reasons for providing security to C-suite executives. Those executives are seen as the face of the company and often bear the brunt of the publicâs gripes against a company. Prominent business leaders, such as business executives, are often the targets of threats due to their affiliation with the company and are in need of protection as a result. Ensuring their safety is often…
On November 7, 2024, for the first time, the Internal Revenue Service (IRS) has made available a form on which elections under Section 83(b) of the Internal Revenue Code may be made. This new Form 15620 provides a standardized method for elections and should streamline the process of making an 83(b) election. However, the new form is not required to be used, and taxpayers may continue to use their own form of election, provided it…
On September 17, 2024, the Israeli Tax Authority (ITA) amended the existing rules governing employee share plan offerings in Israel, effective January 1, 2025. As part of these new rules, the ITA will reactivate dormant reporting obligations for employee share plan offerings in Israel and has also adopted new requirements and procedures for establishing share plan offerings with trustee arrangements. Join Baker McKenzie and Israeli Firms Herzog, Fox & Neeman and Phoenix – ESOP for a…
We have released the September 2024 edition of our “Clients & Friends Newsletter,” which reviews the latest developments impacting share plans globally. Explore the newsletter, and/or register for our upcoming October 8th webinar, to learn more about the impact of the following tax, legal and regulatory changes on your share plans: