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re: Promissory Note/ Sign-on Bonus

Posted on 10/23/15 at 5:51 pm to
Posted by Poodlebrain
Way Right of Rex
Member since Jan 2004
19860 posts
Posted on 10/23/15 at 5:51 pm to
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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