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re: Promissory Note/ Sign-on Bonus
Posted on 10/23/15 at 5:51 pm to MMauler
Posted on 10/23/15 at 5:51 pm to MMauler
No, I mean the step transaction doctrine. The OP admits the intent of the transaction is to award a signing bonus. The economic substance of the transactions is that he got cash now as compensation for accepting employment. He should incur the tax liability associated with the compensation now instead of 2 years from now that the form of the transaction would indicate. To prevent such an abuse the step transaction doctrine treats all transactions as occurring simultaneously instead of in sequence over time.
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