A working paper by Dan Dhaliwal, Merle Erickson, and Shane Heitzman ("Taxes and the Backdating of Stock Option Exercise Dates," University of Arizona,ssrn.com/abstract=954974) found support for the theory that exercise dates were also backdated to maximize the executives' income while minimizing the executives' taxes.
Section 409A will accelerate income recognition from the exercise date to the vesting date.
When considering the FASB rules for stock option accounting, the perceived problem cited by the Senate subcommittee is that, for tax purposes, companies are allowed a tax deduction equal to the difference between the stock's FMV on the exercise date and the stock's cost, which is often higher than the book expense.
The amount subject to tax will be the FMV of the stock on the exercise date, less the exercise price, plus any amount that was paid for the option, if applicable.
We can model this case, for example, using seven exercise dates, at one-month intervals.
An American option can be valued by starting on the expiration date and working sequentially backwards across each exercise date to the current date.
It comes after the Irish Mirror revealed Roz and Bressie had a series of secret
exercise dates - they attended two major sporting events together in one weekend and were joined by his family.
1.861-4 (b)(2)(ii)(G), Example 6, applies the time basis for stock option income to the period between the grant and vesting dates, rather than between the grant and
exercise dates. The example specifically disregards the days worked between the vesting and
exercise dates.
payment on the
exercise date of the future value of $3, in conjunction
