ESPP
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Taxation of Employee - ESPP

423 Qualified ESPPs

No tax at grant or purchase.

At sale, generally capital gain, but ordinary income applies as well for both qualifying and disqualifying dispositions.

Non-Tax Qualified ESPPs

Tax on discount at purchase.

Tax on sale of shares. Long-term capital gain rates apply if shares held more than 1 year.

Sub Deduction - ESPP

423 Qualified ESPPs

Only if disqualifying disposition.

Non-Tax Qualified ESPPs

Yes, no reimbursement required.

Withholding and Reporting

423 Qualified ESPPs Income Tax:

No withholding. Reporting of purchase and sale.

Social Insurance Contribution:

No.

Non-Tax Qualified ESPPs Income Tax:

Yes, on purchase.

Social Insurance Contributions:

Yes, employer pays its share and withholds employee's share.

Securities Restrictions - ESPP

423 Qualified ESPPs

Yes, but simple registration (Form S-8) for public company plans and exemptions are generally available for most private company plans.

Non-Tax Qualified ESPPs

Yes, but simple registrations (Form S-8) applies for public company plans and exemptions are generally available for most private company plans.

Exchange Controls - ESPP

423 Qualified ESPPs

No.

Non-Tax Qualified ESPPs

No.

Plan Entitlement - ESPP

423 Qualified ESPPs

No, but plan generally must cover all employees of parent and designated subsidiaries (certain employees, including part-time and seasonal employees can generally be excluded).

Non-Tax Qualified ESPPs

No.

Data Privacy - ESPP

While there are no federal data privacy requirements, please note, the California Consumer Privacy Act ("CCPA") became effective as of 1 January 2020. The CCPA imposes a broad range of new requirements for the collection and processing of personal data of California residents.

Other U.S. states may have or may adopt similar data privacy requirements.