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On July 11 the IRS released an internal Industry Director Directive memorandum dated June 15, 2007 (the "Directive"), which designates transactions involving backdated stock options as a "Tier I Issue" for IRS agents.Tier I Issues are considered matters of "high strategic importance," The Directive has important implications for both companies and individuals.As drafted, the form IDR is unnecessarily broad and could be interpreted to require the disclosure of needless information.We have found the IRS receptive to amending the request to a more specific set of documentation which addresses the IRS's goals.The Directive is significant, nonetheless, in that it signals a nationally coordinated effort within the IRS to target transactions involving backdated stock options, and also establishes mandatory audit requirements and centralized reporting procedures within the IRS as relating to backdated stock options.

The Directive includes a form IDR for use in any audit of backdated options.First, backdated options raise deductibility issues pursuant to § 162. An exception to this limitation is set forth in Treas. § 1.162- 27(e)(2)(vi), which exempts "qualified performance based compensation" from the

The Directive includes a form IDR for use in any audit of backdated options.

First, backdated options raise deductibility issues pursuant to § 162. An exception to this limitation is set forth in Treas. § 1.162- 27(e)(2)(vi), which exempts "qualified performance based compensation" from the $1 million limitation.

In order to qualify for this exception, the option in question must have an exercise price that equals or exceeds the per share value on the grant date (other requirements also apply). The second tax consideration identified in the Directive focuses on whether an option qualifies as an Incentive Stock Option ("ISO") pursuant to § 422.

Backdating of an option may prevent it from qualifying for the exception set forth in Treas. Backdating of a stock option might prevent such option from qualifying as an ISO as § 422(b)(4) requires that the option's exercise price be not less than the fair market value of the stock at the time such option was granted.

Withholding issues may arise for a corporation if an option that was labeled an ISO is later found to have been misclassified.

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The Directive includes a form IDR for use in any audit of backdated options.First, backdated options raise deductibility issues pursuant to § 162. An exception to this limitation is set forth in Treas. § 1.162- 27(e)(2)(vi), which exempts "qualified performance based compensation" from the $1 million limitation.In order to qualify for this exception, the option in question must have an exercise price that equals or exceeds the per share value on the grant date (other requirements also apply). The second tax consideration identified in the Directive focuses on whether an option qualifies as an Incentive Stock Option ("ISO") pursuant to § 422.Backdating of an option may prevent it from qualifying for the exception set forth in Treas. Backdating of a stock option might prevent such option from qualifying as an ISO as § 422(b)(4) requires that the option's exercise price be not less than the fair market value of the stock at the time such option was granted.Withholding issues may arise for a corporation if an option that was labeled an ISO is later found to have been misclassified.

million limitation.In order to qualify for this exception, the option in question must have an exercise price that equals or exceeds the per share value on the grant date (other requirements also apply). The second tax consideration identified in the Directive focuses on whether an option qualifies as an Incentive Stock Option ("ISO") pursuant to § 422.Backdating of an option may prevent it from qualifying for the exception set forth in Treas. Backdating of a stock option might prevent such option from qualifying as an ISO as § 422(b)(4) requires that the option's exercise price be not less than the fair market value of the stock at the time such option was granted.Withholding issues may arise for a corporation if an option that was labeled an ISO is later found to have been misclassified.

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