There has been exponential growth in recent years in the use of different forms of share-based remuneration by companies to attract, retain, and motivate employees. Many involve options, promises of future shares in the event that certain criteria are met. In a number of cases, however, employees are granted actual stock in the company. The tax implication of share deals can often be complex and contested, particularly around the issue of minority discounts.  A minority discount essentially reflects the notion that a partial ownership interest may be worth less than its proportional share of the total business. So, if a…

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