New IRS Filing Requirement for U.S. Executives with Non-U.S. Compensation

The Alert Memo concerns a new IRS filing requirement for 2011 tax returns that may affect many U.S.-taxpayer executives with compensation awards based on foreign company stock or guaranteed or provided by a foreign company. Employers that are part of corporate groups with non-U.S. parents, and non-U.S. entities that maintain compensation arrangements in which U.S. taxpayers participate, should consider alerting their U.S. executives to this new filing requirement, in order to help them avoid tax penalties.