U.S. and Global Employment Tax Issues
Around Equity Compensation
Phoenix Chapter NASPP
Meeting
Kate Forsyth, Deloitte Tax LLP
David Johnson, Deloitte Tax LLP
Jason Russell, Deloitte Tax LLP
June 11th, 2013
Agenda
Introduction
U.S. payroll deposit rules
Managing non-U.S. employment tax obligations
Business travelers
Global rewards updates
Questions and contact information
1
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
U.S. Payroll Deposit Rules
What is the payroll deposit date?
• Typically, the date the compensation becomes taxable, will trigger the
employment tax liability. The deposit date for that liability, will be based
on the employer’s payroll deposit filing status.
– Monthly deposit schedule — deposit due by the 15th day of the following
month.
– Semi-weekly deposit schedule
• If the payday falls on a Wednesday, Thursday, and/or Friday, then deposit
taxes by the following Wednesday.
• If the payday falls on a Saturday, Sunday, Monday and/or Tuesday, then
deposit taxes by the following Friday
– Deposits are due on business days, if a due date falls on a Saturday, Sunday,
or legal holiday, the deposit is considered timely if it is made on the following
business day.
– There is a next day deposit requirement once the accrued payroll tax liability
exceeds $100,000 (“one day deposit rule”)
3
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Typical liability dates
•
•
•
•
4
NQSOs: Exercise date (T+3)
SARs: Exercise date
RS: Vesting date (or transfer date if 83(b) election is made)
RSUs: Vesting for FICA and stock delivery for FIT
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Field audit memorandum
• On March 14, 2003, a Memorandum was issued by the IRS to audit examiners
to provide guidelines surrounding assessment of employment tax penalties for
NQSOs.
“It has been argued that the shares (or the value of the shares) are not available to the
exerciser of the options until settlement date, and therefore no actual or constructive
payment of wages takes place until that time.
There is generally only a three day delay between time of exercise and time of
settlement resulting from such exercise. In fact, under 17 C.F.R. Sec. 240.15c6-1(a),
the SEC generally established a maximum three day settlement period for brokerdealer trades. There is presently no specific published guidance relative to whether the
date of exercise or date of settlement is the appropriate date for considering assertion
of the penalty for failure to deposit employment taxes attributable to the exercise of
nonqualified stock options.”
• Under this Field Directive, auditors “should not challenge the timeliness of
deposits required under Treas. Reg. § 31.6302-1(c), if such deposits are made
within one day of the settlement date, as long as such settlement date does not
fall more than three days from date of exercise.”
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U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Timing example
• Company has regular payroll on the
1st and 15th of the month. They are
considered a semiweekly depositor
for Federal income taxes.
• Monday, October 15th is their regular
payroll and they had a tax liability of
$50,000
• Wednesday, October 17th they had
an employee settle NQSO’s with a
tax liability of $110,000.
• Based on the next day deposit rule
the $110,000 would be due on
Thursday, October 18th.
• Based on the semiweekly deposit
status and the $50,000 would be due
on Friday, October 19th.
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U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Penalties
• Underpayment penalty
– 2% — One to five days late;
– 5% — Six to 15 days late; and
– 10% for more that 16 days late
• Weekends and holidays are included when calculating penalties
7
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Penalty example
• Company has regular payroll on the 1st and
15th of the month. They are considered a
semiweekly depositor for Federal income taxes.
• Monday, October 15th is their regular payroll
and they had a tax liability of $50,000.
• Wednesday, October 17th they had an
employee settle NQSO’s with a tax liability of
$110,000.
• Instead of making the $110,000 deposit on
October 18th, they lump the amount together
with the Thursday, November 1st liability
and deposit a total of $160,000 on Friday,
November 2nd.
• Under audit, the service would request the
brokerage records and see the settlement date
of October 17th.
• The service would amend the Schedule B
to show the correct liability of $110,000 on
October 17th.
• The deposit of $110,000 should have been
made on Thursday, October 18th.
• The deposit is 15 days late, and subject to
penalty of 5%, or $5,500.
8
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Penalties
• The IRS uses a FIFO system to assign deposits, and will attribute a deposit to
the most recent tax liability. Unfortunately, this can cause a cascading penalty.
• In Rev Proc 2001-58, the Service provides the following example to show how
the FIFO methodology can create cascading penalties:
– For the second calendar quarter of the year, B, a monthly employment tax depositor,
pays its employees on the first of every month. B normally makes deposits on the 25th
(or next banking day thereafter) of each month in which the liability is incurred, instead
of waiting until the 15th day of the following month. B pays its employees on April 1.
B fails to make the deposit on April 25. For May, B pays its employees on May 1. On
May 25 unaware of the underdeposit for April, B makes a deposit to cover its May
liability. The IRS applies this deposit to the most recently ended deposit period — April
— instead of the May liability as intended by B. This cycle of deposits continues until the
end of the quarter. Instead of having a failure-to-deposit penalty only for April, B will be
subject to a penalty for every month in the quarter. B can minimize cascading penalties
and reduce the penalty amount by timely following the IRS’s procedures to designate
May and June as the deposit periods to which the deposits are to be applied.
9
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Penalty mitigation
• The IRS does allow a “safe-harbor” shortfall if the shortfall is no more then the greater of
$100 or 2% of the amount due, so long as the original deposit is made timely, and the
shortfall is made up by the ‘make-up date.’
– Example: A is required to make a deposit of $1,000 on June 15 and is a semi-weekly depositor. A
makes a deposit of $900 on June 15 and would be required to make the additional $100 deposit by
the first Wednesday or Friday occurring on our after July 15th. Because the shortfall is $100 and
they have made up the deposit by the make-up date, no penalties are assessed.
• Taxpayers can designate to which tax period they want a specific deposit applied within
90-days of receipt of a notice of penalty.
Deposit period ending date Due date of deposit
10
Date of deposit that service applies to deposit period and applicable penalty under section 6656
04/05/02
04/10/02
04/10/02
$0
04/12/02
04/17/02
06/26/02
$1,000
04/19/02
04/24/02
04/22/02
$0
04/26/02
05/01/02
04/29/02
$0
05/03/02
05/08/02
05/06/02
$0
05/10/02
05/15/02
05/13/02
$0
05/17/02
05/22/02
05/20/02
$0
05/24/02
05/30/02
05/27/02
$0
05/31/02
06/05/02
06/03/02
$0
06/07/02
06/12/02
06/10/02
$0
06/14/02
06/19/02
06/17/02
$0
06/21/02
06/26/02
06/24/02
$0
06/28/02
07/03/02
07/03/02
TOTAL
PENALTY
U.S. and Global Employment Tax Issues Around Equity Compensation
$0
$ 1,000
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Managing non-U.S.
employment tax obligations
Payroll compliance and equity compensation
• Timing of taxation varies between countries
– Most countries tax at exercise
– Some countries tax at grant, vest or sale
– Exit and trailing tax considerations
• Amount subject to tax varies between countries
– Even for those countries that tax stock options at exercise, there may be
differences in the statutory definition of fair market value
• Italy — average price over the prior month
• China/Taiwan — closing price on date of transaction
• Malaysia — average of high and low on date of transaction
• Administrative infrastructure
• Broker/administrator capabilities
12
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Corporate reporting and tax withholding
• Income and social tax reporting and withholding requirements differ
among various jurisdictions. The administrative burden can be
minimized in some countries through plan design and decisions
regarding the operation of the plan.
• Three “key ingredients” to determine an employer’s responsibility:
1. Plan optimization opportunities/plan design
2. Corporate recharge
3. Administrative methodology
Canada/France/UK — Plan optimization affects conclusion
Brazil/Mexico — Recharge affects conclusion
Belgium — Administrative methodology affects conclusion
13
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Accounting for equity compensation and
ASC 718/FAS123(R)
• ASC 718-10-25-18/Paragraph 35 of FAS 123(R) states that if the number of
shares withheld exceeds the number of shares needed to meet the minimum
statutory withholding rate, the entire award shall be classified as a liability.
– Auditors may assert that this triggers liability accounting for the plan
– The rule impacts awards settled in shares, which generally includes:
• Restricted stock
• RSUs
• Stock settled stock appreciation rights
• If an amount in excess of the minimum statutory requirement is withheld, the
entire award may be classified as a liability.
– The concept of minimum statutory requirement often does not exist outside the U.S.
and in most U.S. states
– Withholding at the minimum statutory amount results in additional liability owed by
employee
* Stock options may be excluded for exercises settled in cash.
14
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Accounting for equity compensation and
ASC 718/FAS123(R) (cont.)
• RSU income is taxable, yet no cash is issued. How does a company
address corporate withholding obligations?
– Net-share-settlement?
• Deliver the shares net of taxes to the employee
• Company pays the cash equivalent of those shares withheld to the tax
authorities
• ASC 718/FAS123R obstacles (see later)
• Increasingly popular to preserve share pool
• Sell-to-cover?
– Shares are sold on the market to cover withholding taxes
• Payroll deduction or employee check?
– Employee receives the gross shares and local payroll withholds taxes from
future income or collects personal check
15
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Accounting for equity compensation and
ASC 718/FAS123(R) (cont.)
• How to address issue?
– Determine appropriate withholding methodology
• No withholding at source
• Withhold actual taxes due for each participant
• Flat rate minimum withholding
– Obtain auditor approval that withholding methodology does not create adverse
accounting implications
• Varying opinions from auditors on this issue
16
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Accounting for equity compensation and
ASC 718/FAS123(R)
Determination of withholding rate
Flat rate determined for each country
Specific rate determined
for each individual
The most accurate
methodology but can be time
consuming to administer for
the HQ and local company as
well as for the brokerage
Based on highest paid
participant
OR
Based on lowest paid
participant
Will likely trigger liability accounting
and as such, is probably unacceptable
to Finance
Will result in under withholding for
many plan participants requiring some
involvement by local payroll to collect
shortfall
Administrative burden
• Post-tax event
Individual
rate
17
• Pre-tax event
• Local payroll
Flat rate
• Local payroll and corporate
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Business Travelers
Who are business travelers?
Business travelers
Individuals traveling on business for periods of varying
lengths of less than one year and often to multiple
countries or states with the potential to be exposed to
other jurisdiction’s tax regimes.
These employees are frequently not on the mobile
employee “radar screen”. They are typically working in
alternate locations on projects, visiting suppliers or
customers, or attending business meetings. They are not
a traditional “expatriate” or “assignee” tracked by Human
Resources.
State to State
Business
Travelers
International
Business
Travelers
Permanent State
to State transfers
Compensation is typically delivered from the home
country/ state employer and may include per diems
and/or expense reimbursements for items such as travel,
accommodation, meals, incidentals, etc.
They typically do not change their residency or tax home
and in most cases, family members do not travel with the
employee.
These employees are not usually covered by a relocation
or assignment policy and there may or may not be a
cross charge to the locality(ies).
Cross-state /
cross-border
commuters
Telecommuters
Similar challenges may be faced by telecommuters and
cross-state/cross-border commuters
19
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Why focus now? – Risks with business travel
Employer
1
Increased
audit risk
4
Legislative
updates
2
Compliance
Increased
Increased
scrutiny
scrutiny
3
Acceptable
risk profile
Home
employer
reporting
Visibility
from
immigration
Corporate
tax nexus
Host
employer
reporting
Processes to efficiently and
effectively analyze tax risks
incorporates numerous
perspectives
Home
individual
tax
Host
individual
tax
Tax program for business travelers
20
Employee
Payroll, income and social tax
• Host and home payroll reporting
and withholding requirements
• Withholding compliance
obligations
• Employer Social Security
obligations; not always in line with
income tax requirements (e.g.,
income tax treaties)
• Incremental employee income and
social tax costs (if equalized)
• Corporate tax - Nexus risks
• Withholding waivers
Income and social tax
• Incremental income and social
tax costs
• Equalization and tax
reconciliations
Reputation
• What would be the impact on the
Company’s reputation if noncompliance was made public?
• How would the Company's
relationship with the tax authority
be affected?
Tax filings
• Tax ID registration/application
• Individual income tax return
filing requirements to claim
foreign tax credits, or treaty
positions
Commercial
• Were the costs of business travel
accurately estimated for budgeting
purposes?
After-tax pay
• Equalization
• Responsible for own taxes
Labor law
• Does the presence of business
travelers in another jurisdiction
expose the Company to labor laws
of that jurisdiction?
Employee experience
• Positive or negative
experiences of process and
travel to host jurisdiction
• Willingness for future
deployment
Immigration
• Ensuring the correct visas and
work permits are obtained
Immigration
• Risks associated with entering
a jurisdiction on the wrong visa
• Detention/deportation
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Challenges with equity
Equity team should be part of the cross functional team that
addresses any business traveler problem – equity is especially
complicated and policy design often does not consider equity
US Domestic
Reporting and withholding
•
Practical
considerations
When / how frequent
do you withhold and
report?
Do you take credits at
the withholding
level?
Current travel data
Tax equalization?
How do deminimis
policies apply to
equity (where
earnings period > 1
year; or where vest
happens before
policy is exceeded)
•
•
•
•
•
21
•
•
•
•
•
•
•
Each state has
different rules
Day 1 (CA)
Difference between
salary and equity
(NY)
Does not recognize
travelers (IL)
Reverse credits (CA
and OR)
Equity sourcing
Recognition of treaty
U.S. and Global Employment Tax Issues Around Equity Compensation
International
•
•
•
•
Is there a treaty
between home and
host countries?
What are the tax
exemption
requirements? Such
as days of physical
presence, cost
charges.
The “183 Day Rule”
Treaty protection
may not aliviate
employer compliance
obligations (e.g., tax
withholding waivers
in Canada and the
UK)
Copyright © 2012 Deloitte Development LLC. All rights reserved.
Business Traveler Approach
Key observations
• The majority of large market cap companies have a 2013 initiative to ensure that they
can reasonably meet their compliance requirements with respect to business travelers,
where they had not previously addressed this risk.
• Many companies who have historically tried to address business travelers with varying
degrees of success.
• Companies that address their business traveler compliance obligations:
 usually apply business thresholds such as de-minimis days
 tax equalize business travel income, including equity
 obtain travel data from a variety of sources such as travel expenses, booked
travel and self identification
 have not been able to address their compliance obligations through payroll
reporting and remittance. For these companies, it is common practice that
employee tax return support is provided to mitigate risks.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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Global Rewards Updates
China: Intensified SAFE and Tax Registration
requirements of equity awards
• Background: Many multi-national companies are required to comply with a
number of registration and reporting requirements with respect to equity awards
in China such as State Administration of Foreign Exchange (SAFE) registration
and Tax registration.
With increased volumes of equity compensation, the tax and SAFE authorities
have grown the level of scrutiny of the registration process.
• SAFE Registration: On 20 February 2012, SAFE issued Circular 7 to
supersede Circular 78 which emphasizes the employer’s obligation to comply
with registration requirements and signals the authorities’ continual efforts to
strengthen reporting and administration in this area. Various provinces have
started to implemented different steps to streamline as per Circular 7.
• Beijing is requesting for re-registration of the already registered existing plan.
• All provinces are reviewing the registered plans and strict follow-ups to get
more information on the equity plans.
• Chances of penalties for non-compliance of SAFE process have increased
significantly owing to formal guidelines issued to local SAFE authorities.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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China: Intensified SAFE and Tax Registration
Requirements of equity award
• Tax Registration: All equity plans offered in China must be registered with the
company’s in-charge tax bureau(s) prior to the roll out of the equity plan. Failure
to fulfil this regulatory requirement would result in penalties to the company and
further disqualify participants from adopting the preferential tax treatment on
equity gains.
• Beijing tax bureaus have started adopting formal procedures under which a
list of documents are requested for review and approval purposes.
• Some Beijing tax bureaus have also set for on-site review with
company/authorized agent to conduct a thorough review of the documents
submitted in order to complete registration.
• Shanghai province have been seeing increasing number of penalty instances
for failure or untimely registration of plans.
• Provincial tax bureaus have also set a standardized processes for tax
registration and on-going reporting requirements.
• Conclusion: Any company offering equity plans in China are required to
evaluate the potential risks of unregistered plans or monitor the need for reregistering plans and adhere to increased compliance.
25
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U.S. and Global Employment Tax Issues Around Equity Compensation
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French 2013 Finance Bill – Impacts to Taxation of
Equity Awards and Capital Gains
• Background: On 29 December 2012, France’s Constitutional Court issued its decision on
measures in the 2013 Finance Law, concluding that all the measures affecting companies
were valid, but striking down some controversial provisions relating to individuals.
• 75% Tax: The Constitutional Court struck down the 75% tax on professional income over
EUR 1 million. Re-proposal of a similar tax for 2013 income may occur.
• Impact to French tax qualified equity awards (employees): Flat preferential rates will
continue to apply for awards granted before September 28, 2012. New income and social
surtax rates will apply to awards granted on or after September 28, 2012:
Changes implied by the Financial Act for 2013
Qualified Awards (Granted as of 9-28-2012) - Taxes Paid at
Sale
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Non-Qualified - Taxes Paid at Taxable Event
Income Tax
Up to 45%
Income Tax
Up to 45%
Additional Social Taxes
8%
(of which 5.1% will be
deductible)
Employee social contribution
from 23% to 8.85%
(rate decreases as earnings increase)
Employee social contribution
10% (sales after Aug. 17,2012)
High Income Contribution
3% or 4%
High income contribution
3% or 4%
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
French 2013 Finance Bill – Impacts to Taxation of
Equity Awards and Capital Gains
• Impact to French tax qualified equity awards (employer): Flat 30%
social tax rate will continue to apply at the time of grant.
• Impact on capital gains:
- Capital gains on shares: Taxed at the progressive income tax rates, up to 45%.
- High income contribution of 3% or 4%.
- Taper relief on taxable capital gain will be available depending on the holding period of
the shares prior to sale:
•
20% for shares held between two and four years
•
30% for shares held from four to six years
•
40% for shares held during more than six years.
- Social surtaxes of 15.5% remain applicable on the full capital gain (5.1% is deductible).
27
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U.S. and Global Employment Tax Issues Around Equity Compensation
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Ireland: Restricted Stock Units (RSUs) –
Cross Border Taxation
• Background: On 14 December 2012, Irish Revenue issued official guidance on how RSUs should
be treated for Irish tax purposes in cross-border situations.
• Key considerations:
• 100% if resident in Ireland at taxable event; and
• Not taxable if non-resident at taxable event.
• Double tax relief will be allowed when employees file resident returns at yearend.
• Conditions for the “real-time” foreign tax credit: To apply the foreign tax credit mechanism
through payroll, the conditions are as follows:
‾ Ireland has a tax treaty with the country where there is tax withholding due
‾ Employee’s annual personal income tax return must be filed by 31st March of following year;
‾ The employer must provide information reporting to Revenue by 31st March of the following tax
year; and
‾ Evidence of deduction of foreign income tax at source (which must be nonrefundable) must be
available for production if requested by the Revenue.
Note: Where the conditions are not met, Revenue will make an estimate of the full amounts due and
the standard interest and penalty provisions will apply.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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Ireland: Restricted Stock Units (RSUs) –
Cross Border Taxation
• Action steps:
• Employers should consider whether to administer the “real-time” foreign tax
credit relief at the payroll withholding/reporting stage for Ireland inbound
employees.
• Setup an internal process to apply the relief and work with payroll provider to
ensure adjustments are properly reported through payroll.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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United Kingdom: Various New Proposals that
could Impact Equity Compensation
• Various Proposals by the Office of Tax Simplification:
• Employer reporting and withholding:
‾ Form 42 should be released at the start of the tax year to enable employers
to complete the form throughout the year rather than completing at once at
the tax year end.
‾ Online filing of Form 42 should be introduced to reduce the administration
burden. Form 42 should eventually be integrated into the real time
information (RTI) reporting.
‾ PAYE withholding tax remittance date should be extended from 14 days to
60 days following the tax month end.
‾ PAYE arising from equity compensation should be removed from the
section 222 charge if the tax is ‘made good’. Note: Currently, under
section 222 ITEPA 2003, where the company does not recover the PAYE
due on a notional payment such as options exercise within 90 days, the
amount of PAYE due is treated as additional income for employee.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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United Kingdom: Government’s response to the
Office of Tax Simplification’s (OTS) proposed
changes
– Employer Reporting and Withholding:
‒ The OTS proposed online filing to replace existing paper-based annual return (Form42) and share plan reporting to be integrated to real-time information (RTI) reporting
where payroll withholding applies. HMRC will proceed with implementing online filing
of Form-42 to implement in 2014 and will look into intelligent filing recommendations.
‒ Integration of share plan reporting into RTI would be looked into once Form-42 online
implementation is completed.
‾
‾
31
31
The government will implement the OTS recommendation to extend the deadline for
tax withheld to be paid to HMRC once the RTI is fully implemented. OTS
recommends to extend withheld payment due date to 60 days following the month
end of taxable event but no later than 31 May following the end of tax year.
The government will consult on a modification to extend the due date to recover the
applicable withholding amount from current 90 day to 6 July following the end of the
tax year.
U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
United Kingdom: Form 42 submission: July 6,
2013
•
Background:
‾ The Her Majesty’s Revenue and Customs (HMRC) require companies to report any
employee-related share plan transactions during the UK tax-year (April 6 – April 5) on
Form-42 by July 6 following the tax year end default of which may attract penalty.
•
Relevant to Non-UK companies & Penalties: Most non-UK companies are unaware of
this obligations even though they are required to report share plan details provided to UK
employees.
‾ Late filing of Form-42 attracts an initial penalty of £300 per reportable event and
further penalties can be up to £60 per day.
‾ Penalties for incorrect return can also up to £3,000.
‾ Late or incorrect submissions affects the tax risk profile of the company; HMRC are
more likely to focus their attention on those companies that miss filing reportable
event deadlines or make errors in their reporting.
•
Reportable events: The reportable events include wide spectrum of events such as grant
and exercise of stock options, the award and vesting of restricted stock units and even
the acquisition of stock at market value. Any of these activities may trigger the need to
submit a Form-42
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U.S. and Global Employment Tax Issues Around Equity Compensation
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United Kingdom: Form 42 submission: July 6,
2013
– Conclusion: A Form-42 reporting obligation for non-UK parent companies can
arise where stock awards are held by:
‒ UK employees in a non-UK-based parent company.
‒ Non-UK employees in respect of duties or workdays in the UK
‒ Internationally mobile employees
This is an area of focus for HMRC and non-UK companies should submit a
Form-42 through a responsible person such as an officer of the UK employer or
the parent company who signs the submission.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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Questions?
Deloitte contact information
Kate Forsyth
Global Employer Services
Deloitte Tax LLP
David Johnson
Global Employer Services
Deloitte Tax LLP
Tel/Direct: 213-593-4279
kforsyth@deloitte.com
Tel/Direct: 206-716-6781
davidejohnson@deloitte.com
Jason Russell
Global Employer Services
Deloitte Tax LLP
Tel/Direct: 415-783-5376
jasrussell@deloitte.com
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U.S. and Global Employment Tax Issues Around Equity Compensation
Copyright © 2012 Deloitte Development LLC. All rights reserved.
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U.S. and Global Employment Tax Issues Around Equity Compensation
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