`ANNEX`

U.S. Income Tax Treaty — Technical Explanation - 2003 · 2026-10-03 edition · updated 2026-10-04 · United States

These fact patterns were developed to aid the discussion related to the treatment of stock options under the Convention.

Each fact pattern below is based on the following common facts:

0 A stock option with a price of option 15, which is equal to the value of the stock, is granted to an employee.

0 The employee exercisesthe option in 5 year, acquiringthe stock for 15. At the time

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▸Contents — U.S. Income Tax Treaty — Technical Explanation - 2003

U.S. Income Tax Treaty — Technical Explanation - 2003

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