Page 228 - International Taxation IRS Training Guides

Excise Tax on
Stock-Based Compensation

of Expatriated Corporation

 Excise tax under IRC 4985 on certain stock-based

compensation of
corporate insiders when a domestic

corporation becomes an expatriated corporation

through an inversion transaction in which a

the domestic corporation recognizes
shareholder of

gain

 TCJA
modifies the excise tax from 15% to 20%

that first become surrogate
 Effective for corporations

Dec. 22, 2017
foreign corporations after

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