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If Morris and Brad resolve their negotiations through the use of stock options, careful tax analysis is again necessary. The Code treats stock options in three ways depending on the circumstances, and some of these circumstances are well within the control of the parties (see Exhibit 11.5). If a stock option has a readily ascertainable value, the IRS will expect the employee to include in his taxable income the difference between the value of the option and the amount paid for it (the amount paid is normally zero). Measured in that way, the value of an option might be quite small, especially if the exercise price is close or equal to the then fair market value of the underlying stock. After all, the value of a right to buy $10 of stock for $10 is only the speculative value of having that right when the underlying value has increased. That amount is then taxed as ordinary compensation income, and the employer receives a compensating deduction for compensation paid. When the employee exercises the option, the Code imposes no tax, nor does the employer receive any further deduction. Finally, should the employee sell the stock, the difference between, on the one hand, the price received and on the other the total of the previously taxed income and the amounts paid for the option and the stock is included in his income as a capital gain. No deduction is then granted to the employer since the employee s decision to sell his stock is not deemed to be related to the employer s compensation policy. This taxation scenario is normally quite attractive to the employee because she is taxed upon a rather small amount at first, escapes tax entirely upon java upc-a reader UPC-A Java Control- UPC-A barcode generator with free Java sample
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