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…
I hope most of you have seen our client alert on the recent Israeli Supreme Court ruling that confirmed that stock-based compensation has to be included in the cost base of Israeli subsidiaries of multinational companies. As a result of the decision, we have already seen a flurry of activity as many companies are evaluating how to obtain a tax deduction for awards granted to Israeli employees. As a reminder, for companies with a cost-plus…
Under current law, taxpayers who hold multiple lots of the same shares can identify which shares are considered sold for purposes of calculating capital gains. Section 13533 of the Senate tax bill would eliminate this flexibility and mandate a first-in, first out (FIFO) approach. This will adversely impact employees who have acquired low cost basis company shares in the past and continue to hold those shares. The obvious – Following enactment, employees will want to…