U.S. companies are increasingly providing equity compensation to employees who live abroad. Such grants may include stock options, restricted stock, and restricted stock units issued either directly from the U.S. company or from a foreign subsidiary. For U.S. taxpayers living abroad, such equity compensation creates multiple tax issues, both at the time of receipt, as well as upon disposition.
The presentation will provide an overview of the tax issues facing U.S. taxpayers living abroad who receive equity compensation. The presenters will focus on options for taxpayers to consider as they receive and sell equity throughout the lifecycle of a company, from startup to IPO. Topics will include: U.S. taxpayer status, vesting considerations (including section 83(b) elections and related tax-minimization strategies at time of grant), as well as options to minimize tax at the time of sale, such as qualified small business stock/rollover transactions, qualified opportunity zones investments, and expatriation.