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International mobility

A rule change could have devastating consequences for globetrotting employees


  • Proposed changes to the taxation of employment-related securities could have unforeseen consequences.
  • A comparison of the present and proposed tax treatment of share options.
  • The new legislation will apply regardless of residence status when the option or right was initially offered.
  • A practical example illustrates the potential liability.
  • All existing share incentive awards of internationally mobile employees should be urgently reviewed.

The rather incongruous phrase “be careful what you wish for it might just come true” could equally be attributed to Aesop’s Fables or Lord (Jeffrey) Archer the former coining the maxim and the latter drawing on the first half of it for the title of his latest novel.

But regardless of literary tastes many internationally mobile employees or “IMEs” (one of the...

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