SALT Planning for Stock Options, RSUs, and Deferred Compensation: State Taxation of Nonresident Equity Awards

This webinar will examine the state and local tax planning challenges associated with stock options, RSUs, deferred compensation, and similar equity-based compensation arrangements, with a particular focus on nonresident sourcing and apportionment issues. Our panel of deferred compensation experts will draw on recent New York and California legislation—including administrative rulings and Office of Tax Appeals decisions—to illustrate how states continue to assert taxing jurisdiction over equity compensation earned across multiple states.

Stock options, RSUs, and other deferred compensation arrangements often create unexpected state tax exposure when employees change residency, perform services in multiple states, or realize income years after the underlying services were performed. New York and California apply detailed and sometimes aggressive sourcing methodologies—often relying on workday-based apportionment during the grant-to-vest or grant-to-exercise period—that can materially increase a nonresident's state tax liability.

The program will devote special attention to California's Appeal of Prince decision and related administrative guidance, which reaffirm the Franchise Tax Board's preferred allocation methodologies and place a significant evidentiary burden on taxpayers seeking alternative or equitable apportionment. The panel will also contrast California's approach with New York's and other state guidelines for sourcing equity compensation.

Listen as our panel of seasoned SALT practitioners explains how states continue to assert taxing authority over equity-based awards earned across state lines and offers advice on identifying potential exposure risks and supporting alternative sourcing positions.