Tax regulators want to block an arrangement that some executives have used to cut taxes related to stock options.[@@]
The Internal Revenue Service has unveiled a new settlement program for users of the strategy, which sometimes relies on annuities, and similar strategies in Announcement 2005-19.
The program, which could affect about 175 executives, is open to executives who have transferred stock options to limited partnerships or other entities owned by the executives and their family members, according to the announcement, which was written by a group of IRS officials led by Stephen Tackney and Rebecca Asta.
The limited partnerships or other entities paid executives for the stock options with annuities or notes.
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Executives who transferred options to limited partnerships before July 2, 2003, and are not yet involved in court proceedings concerning the tax treatment of the transactions can settle with the IRS by taking a number of steps.