The following article is reprinted from The M&A Tax Report, Vol. 12, No. 1, August 2003, Panel Publishers, New York, NY.
EXECUTIVE OPTION? NOT SO FAST...
By Robert W. Wood
It wasn't too long ago that stock options
were in the news primarily for their treatment for financial statement
purposes. Should there be a charge to earnings, and if so, when? Stock
options have also been in the news for AMT problems. Given the dot.com
bust, as well as a more general stock market decline, many recipients of
incentive stock options found themselves (quite painfully) caught by the
AMT preference on ISOs.
Now, yet another stock option flap has
hit the press, this time involving the Service's continuing tax shelter
crackdown. This particular shelter came in several variations, but was
essentially a tax shelter marketed by accounting firms to executives to
defer tax on their options. See McKinnon and Bryan-Low, "IRS Targets Shelter
for Stock Options," Wall Street Journal, July 2, 2003, p. A3.
Treasury Strikes Back
In July, the IRS issued Notice 2003-47,
2003-30 I.R.B. 1. The transaction the Service has targeted involves the
grantee of nonstatutory compensatory stock options. The idea is that the
recipient of options turns around and transfers the option to a related
person. That transferee may be a family member or an entity in which the
individual (or members of his family) hold a substantial interest. Partnerships
are often used.
At the time this transfer is made, the
related person will pay an amount that is purportedly equal to the fair
market value of the option. This payment is generally in the form of a
long-term unsecured and negotiable note, calling for a balloon payment
of the purchase price at the end of the note term. Since the term is often
very long (like 30 years!), the idea is to defer taxes as long as possible.
In some of these deals the forms of payment include other deferred payment
obligations, cash or combinations of these, but the long-term unsecured
balloon note seems to be the most common. The related party making this
purchase is often a thinly capitalized entity with no operating business.
The terms of the note often fail to reflect the risk of nonpayment.
The promoters of this kind of arrangement
argue that the options should be treated as sold or otherwise disposed
of in an arms' length transaction. Under Regulation Section 1.83-7, that
means that the individual does not recognize compensation income when the
related person exercises the options. Furthermore, if the related person
pays for the option with a note or other deferred payment obligation, the
promoters argue that the individual does not recognize compensation income
for the purchase price until the related party actually pays the amounts
due under the note or the other deferred payment obligation.
End Game
Not surprisingly, the Service indicates
it is challenging the transaction. The list of the grounds for challenges
is not long, but includes a couple of heavy hitters. First, the Service
agrees that where an option does not have a readily ascertainable fair
market value at the time of grant, a triggering event can be a sale between
unrelated parties at arms' length. Of course, that is not what these deals
are.
Indeed, the Service says that the transactions
at which Notice 2003-47 is directed "rarely, if ever, reflect terms that
would be agreed to between unrelated parties dealing at arms' length."
The notice also takes issue with the treatment of the deferred payment
obligation. The Service casts a wide net, stating that in any case in which
the transaction includes the disposition of an option without a readily
ascertainable fair market value at the time of grant, and the individual
receives a deferred payment obligation, the IRS will challenge any deferral
of income with respect to that deferred payment obligation. This challenge
applies, incidentally, regardless of whether the transaction is treated
as arms' length or not for purposes of Reg. §1.83-7.
The consequence is pretty significant.
The IRS will argue that the recipient of the option recognizes income to
the extent that the amount of the deferred payment obligation transferred
to the option recipient, plus any cash or other property received by the
individual, exceeds the amount (if any) that the option recipient paid
for the option.
Mismatch
There is also something in the notice about
mismatching. Under Section 83(h), the payor (the issuer of the options)
can claim a tax deduction for the compensation attributable to the transfer
of the option only when the person who performed the services includes
that amount in income. The Service wants to insure that there is no mismatching
of income and deductions between the parties.
Finally, the Service notes that there are
other bases on which the Service could challenge the types of transactions
referred to above. Here, the Service threw in a kind of laundry list -
a kind of "just in case we need it" litany of black marks. They include:
Arguing that the related entity to whom the
option is sold is not bona fide.
The related entity lacks substance.
The related entity lacks a business purpose.
The deferred payment obligation lacks substance. Proposed Regulations
To target this perceived abuse, the Service
has taken a closer look at the regulations under Section 83, the Service
has issued final regulations. The regulations provide that a sale or other
disposition of a nonstatutory stock option to a related person will not
be treated as a transaction that closes the application of Section 83 with
respect to that option. One of the key issues, of course, is what constitutes
a "related person." Here, the Service casts a wide net, generally using
a 20% standard rather than a 50% standard within the context of Section
267 and Section 707. Although I am glossing over some of the complexity
and detail here, just think of this as a heightened sense of targeted relationships.
Is anyone still planning on making huge
gains on stock options? (The answer is surely yes, though not to the degree
that it was just a few years ago.) Wouldn't it be great if you could defer
all of your tax on gains from stock options beyond the exercise date? Wouldn't
it be great if you could convert the triggering tax event for nonqualified
options until disposition (sort of like a hybrid between nonqualified options
and incentive stock options)? The answer to all these things is surely
yes, which is why the Service has addressed this problem, perhaps later
than it should have.
Executive Option? Not
So Fast..., Vol. 12, No. 1, The M&A Tax Report (August 2003), p. 1.