For today’s blog, we have a special guest entry from Emily Cervino of Fidelity Stock Plan Services on a subject near and dear to my heart: defining FMV as the prior day close for purposes of determining taxable gain on award vesting events and the price of shares purchased under your ESPP.
What a Difference a Day Makes! Considering Prior Day Close
By Emily Cervino of Fidelity Stock Plan Services
At the recent NASPP Annual Conference in Houston, I had the opportunity to present “This Ain’t My First Rodeo: Lessons Learned about Equity Compensation.” I took advantage of the new format introduced at the conference: laser-focused, 20-minute sessions during breaks—as an alternative to the traditional, more in-depth breakout panels. I love this format. Short sessions appeal to conference-goers who are looking to cram in as much learning as possible, as well as those whose shorter attention spans make an hour-long, detailed session a hard sell.
I broke this micro-session into even smaller bits and used it as an opportunity to talk about four concepts that can make equity professionals’ lives easier. One concept, which I’d like to review here, is reconsidering the fair market value (FMV) definitions used for equity awards. FMV is an important concept used to set the price on stock options, calculate the taxable income on cash exercise and restricted releases, and determine the purchase price for ESPP.
Back when I started out, things were simpler. FMV was used for grant pricing, and, when it came to calculating taxable income on stock option exercises, where the vast majority of transactions were same-day sales, the actual sale price was utilized. Today, the equity landscape has changed dramatically. The majority of grants now come in the form of restricted stock, which doesn’t include an exercise. Rather, as a time-based vehicle, restricted stock releases (creating a taxable event) are based on a preset schedule.
According to the NASPP Stock Plan Design Survey, 87% of companies use close or average as the FMV to calculate taxable income on restricted stock.(1) Among clients of Fidelity Stock Plan Services, we see very similar results, with 85% of companies using close or average.(2) Which means, for most companies, taxable income can’t be calculated until the market closes on vest date. The exceptions (12% of NASPP responses, 13% of Fidelity clients) are using prior day close (or average), a better option that provides them with a full additional day for calculations! That means on the day before vest date, the FMV is determined as of market close, and the restricted release process can begin, allowing shares to be delivered to participants sooner.
And the benefits don’t end there. This is also a great strategy for ESPP. NASPP doesn’t specifically ask about FMV for ESPP, but in the Fidelity client base, while close and average still rule, we see 5% using prior day close, and a full 20% using current day open price as FMV, providing the benefit of extra hours to one-in-four companies processing their ESPP.
So why do most companies stick with close or average? This may be one of those things that falls into the “we’ve always done it this way” category. While many companies have changed the award types they grant, their FMV definition hasn’t yet evolved.
Plan Sponsors should check out their plan documents. It may be that FMV is only defined for grant pricing, where close or average is a great strategy. The plan document may provide flexibility with respect to the FMV used for tax purposes and/or ESPP. Even if the plan prescribes close or average FMV for tax and/or ESPP, a switch to prior day close (or current day open price) could be effected at the board or committee level and would not require shareholder approval.
Check it out! The gift of time is priceless.
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[1] 2016 NASPP Domestic Stock Plan Design Survey (co-sponsored by Deloitte Consulting LLP)
2 Fidelity client base, as of 9/30/2016
Emily Cervino is a Vice President at Fidelity Stock Plan Services. She has been an active participant in the equity compensation industry since 1998, and now focuses on strategic marketing initiatives, thought leadership, and building Fidelity’s strong industry presence.
Emily is a frequent speaker at equity compensation events, past president of the Silicon Valley Chapter of the NASPP, a member of NASPP, GEO, and NCEO, and a 2015 recipient of the NASPP’s Individual Achievement Award. Emily is a Certified Equity Professional (CEP) and she holds Series 7 and 63 securities registrations.
Views expressed are as of the date indicated and may change based on market and other conditions. Unless otherwise noted, the opinions provided are those of the author, and not necessarily those of Fidelity Investments.
Links to third-party websites may be shared on this page. Those sites are unaffiliated with Fidelity. Fidelity has not been involved in the preparation of the content supplied at the unaffiliated site and does not guarantee or assume any responsibility for its content.
Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917. 780300.1.0
At the CEP Symposium later this month, I am part of a panel that will present on social media strategies that we can leverage in stock plan education programs. Recently, one of my co-panelists, Emily Cervino of Fidelity Stock Plan Services, wrote an article about this topic. I’m so excited about this idea that I asked Emily if we could publish her article as a guest blog entry.
3 Social Media Tricks to Make Stock-Plan Communications Irresistible
By Emily Cervino, Fidelity Stock Plan Services
Did you click on this article because, surely, you have the time to read just three things? And who doesn’t want “irresistible” communications? A quick read could make you a certified hero at work!
I hope you found the title catchy, compelling, and irresistible, because that was my intention. The title is my attempt at “clickbait”—a title that tempts you with information you need and want—but that you have to click to get. The main purpose of clickbait is to attract attention—simply by getting readers to click on it.
I’m gearing up for the CEP Symposium, where I’ll join Aftab Ibrahim, T-Mobile, and Barbara Baksa, NASPP, for a session on using social media tricks to make stock plan communications compelling. No, we aren’t talking about using actual social media for stock plan communications—that’s a no-go from the get-go for many companies. But we are interested in taking the tricks that make social media so addictive and applying them to stock plan communications.
If you are reading this article, you’re on social media and I’d wager that this isn’t your first foray into social media today. I can’t honestly say that I check social media every morning before I get out of bed, but it is a safe bet that by the time I’m done with my 2 minutes of teeth brushing (as recommended by the ADA) I’ve peeked at social media. Sometimes I brush even longer because, you know, one thing leads to another and I clicked here and then there, and then there’s a 30-second video I just have to finish!
Imagine a world where your employees eagerly gobble up your communications, clicking on videos and racing from article to article to absorb the nuggets of stock plan wisdom. Envision employees gathered in the break room sharing ESPP videos on their phone screens. And, treat yourself to the thought that employees look forward to this stuff, rather than approach it with the same enthusiasm as completing their tax return. It isn’t that outlandish. There are some simple, easy things that you can do. While you can go all out with expensive and custom work, there are a number of impactful changes—surefire tricks, as promised—that you can implement today.
Clickbait. Rethink your titles and subject lines to get your audience’s attention. Remember: You want them to open an email or click on a link. The words you choose need to drive action. Which are you more likely to read: “ESPP enrollment window closes on Friday. Enroll today” or “Top benefits you’ll miss out on if you don’t enroll in ESPP by Friday”?
Listicles. No, this is not a made-up word to try to get another click. A “listicle” is an article in a list format. It is easy to organize thoughts into lists, and short lists are tempting to read. Which sounds more compelling, “Equity plan: frequently asked questions” or “5 critical things to know about your stock grant”? When you use listicles, keep them short. Trying to tempt employees to read “36 Tips for Tax Time” is a tough sell. Admit it—you’ve scrolled through an article to check the length before you committed to reading it, haven’t you? Bonus tip: Listicle titles make great clickbait.
Interactive quizzes. I’m sure many of us have been lured in by these social media gems: quizzes that rate us on whether we can identify more movie stars than the average person or spot grammar errors or identify exotic foods. Try this out on stock plan topics with a simple five-question quiz. Don’t make it too hard—people like to succeed—and be sure to connect your participants with more information. For example, reward those who score 4-5 with “Congrats! You are a Stock Plan Pro. You are ready for our advanced topics (with a link to deeper content)” or, for those who score less than 4, “Looks like you could benefit from our video on stock plan basics. (with link to video).”
When you are browsing through different forms of social media, take note of what attracts your attention and contemplate if those attention-grabbing tricks can be integrated into your stock plan communications. And, if you are in the Silicon Valley, please try to join us for the CEP Symposium on March 28. We have a session packed full of examples and activities designed to get all attendees to rethink their approach to communications. #ThisSessionRocks.
Emily Cervino is a Vice President at Fidelity Stock Plan Services. She has been an active participant in the equity compensation industry since 1998, and now focuses on strategic marketing initiatives, thought leadership, and building Fidelity’s strong industry presence.
Emily is a frequent speaker at equity compensation events, past president of the Silicon Valley Chapter of the NASPP, a member of NASPP, GEO, and NCEO, and a 2015 recipient of the NASPP’s Individual Achievement Award. Emily is a Certified Equity Professional (CEP) and she holds Series 7 and 63 securities registrations.
Views expressed are as of the date indicated and may change based on market and other conditions. Unless otherwise noted, the opinions provided are those of the author, and not necessarily those of Fidelity Investments.
Links to third-party web sites may be shared on this page. Those sites are unaffiliated with Fidelity. Fidelity has not been involved in the preparation of the content supplied at the unaffiliated site and does not guarantee or assume any responsibility for its content.
Fidelity Brokerage Services LLC, Member NYSE, SIPC, 900 Salem Street, Smithfield, RI 02917. 791858.1.0
In our upcoming session, “Tracking Disqualifying Dispositions: The Hunt for Tax Deductions”, I will be presenting with Claudia Baranowski from Illumina, Kenny Lockett from AST Equity Plan Solutions, and Michael Myers from Morgan Stanley Smith Barney as we explore the complexities of ISO and ESPP dispositions. We’ll go over the technical tax implications for different sale scenarios, however, the area that sets this presentation apart is our discussion of effective practices we have applied or encountered across the industry for improving your tracking process and employee response rate. Our goal is to identify the tools that every stock plan administrator should know to ensure proper Form W-2 reporting while leaving no possible tax deduction behind.
Our session will cover what should be on your disposition radar. From obtaining information for sales linked to ESPP shares where the employee left the company decades ago to leveraging technology to increase survey responses, our panel will identify the challenging areas of disposition tracking and discuss practices for maximizing success. We will also discuss tailoring your employee education materials to improve response rates (and consequently increase tax deductions in the case of disqualifying dispositions). Perhaps most importantly, we will identify often overlooked resources where administrators can seek help.
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Doreen Lilienfeld of Shearman & Sterling, who will lead the session “Deliverance: How to Make Sure You Can Deliver Shares under Your Plan in Compliance with the Securities Act.”
Deliverance: How to Make Sure You Can Deliver Shares under Your Plan in Compliance with the Securities Act By Doreen Lilienfeld of Shearman & Sterling
Equity compensation offerings are rolled out every day, but too often securities law requirements and other compliance issues applicable to these plans are overlooked. Grants of stock options, RSUs and similar awards generally constitute a “sale” of securities under the 1933 Act and must be registered with the Securities and Exchange Commission unless an exemption from registration is available. Each state also has its own securities law regime that must be reviewed, particularly for private companies and foreign entities relying on an exemption from registration.
While compliance is generally simple, the consequences for failure to comply can be grave. At our session “Deliverance: How to Make Sure You Can Deliver Shares under Your Plan in Compliance with the Securities Act” (Session 10.1), we will walk you through the basics of the Securities Act of 1933 and how they interact with the implementation of equity plans. This includes:
When an offer of securities is made that triggers registration obligations;
Available federal exemptions from registration;
Compliance with state “blue sky” securities laws;
Filing requirements and mechanics for registration statements on Form S-8, including prospectus delivery requirements and ongoing compliance issues;
Consequences of a failure to file required reports with the SEC on an outstanding Form S-8 (such as Forms 8-K, 10-Q and 10-K);
Annual reporting obligations on Form 11-K;
Requirements with respect to “restricted securities” under Rule 144;
Issues for non-US companies; and
Recission rights and other consequences of noncompliance.
Our panel will help you spot securities law issues before grants are made, provide tips on how to ensure compliance and make suggestions on what to do if something went wrong.
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Bill Dillhoefer of Net Worth Strategies, who will lead the session “Supercharging Your Stock Option Grants.” 10 pts to Bill for successfully using the word “quants” in his entry!
My company has been providing equity compensation decision support services since 1999 so we have witnessed firsthand a great deal of the development in stock plan participant education. Here’s a brief summary…. The internet bubble (1995 – 2000) instigated many companies to begin offering broad-based employee stock option programs. These companies had to provide participants with basic information about their stock option grants because options were new and mysterious. This was the “Options 101” phase because these communication programs generally avoided the more complex aspects of stock options.
This early phase of participant education may have transitioned into one that addressed advanced topics had it not been for two major factors. First, the internet bubble burst, causing the appeal of stock options to decline because underwater grants were perceived as worthless. Second was the adoption of FAS 123(R), which eventually resulted in the curtailment of broad-based option programs and the increase in popularity of restricted stock/units. Consequently, the adoption of advanced stock option education programs never gained popularity among issuing companies.
Nevertheless, stock options are still a widely used means of granting equity to valued employees. Even if your company isn’t currently granting new stock options, if your employees have outstanding options grants you can significantly increase their perceived value. It is often said that “perception is reality” so by simply educating participants on the Black Scholes value of their grants, this value become a reality. Now you are probably thinking this is crazy because Black Scholes is WAY over their heads and will only serve to confuse and discourage people. On the contrary, learn the secrets and benefits of providing employees with Black Scholes based information by attending “Supercharging Your Stock Option Grants” at the 20th Annual NASPP Conference.
This presentation consists of four sections. Professor Anne Farrell will present academic research showing that individuals misunderstand the full value of their employee stock options and how basic training can significantly change their subjective valuations. Next, I will introduce two time value based metrics: Forfeit Value and the Insight Ratio. These metrics can be incorporated into stock option communication programs and can increase retention and motivation by helping employees make informed decisions. In the third section, Clinton Shoap from Cargill, Inc. will provide examples of how they have successfully used time value information with their employees. Finally, Larry Bohrer from Charles Schwab will describe their approach to helping companies to realize the full potential of their option awards and how complicated concepts can be understood by participants when presented in the right framework.
Who says Black Scholes is only for quants? Delivered in the right manner Black Scholes information can be fun and profitable for employees with stock options. “Supercharging Your Stock Option Grants” should not be missed.
One of the most common types of “unplanned” modifications I see in my consulting work, which we will cover in our presentation, is that of vesting modifications.
The text of the ASC 718 standard says this about modification accounting: Modifications of Awards of Equity Instruments
51. A modification of the terms or conditions of an equity award shall be treated as an exchange of the original award for a new award. …In substance, the entity repurchases the original instrument by issuing a new instrument of equal or greater value, incurring additional compensation cost for any incremental value. The effects of a modification shall be measured as follows:
a. Incremental compensation cost shall be measured as the excess, if any, of the fair value of the modified award determined in accordance with the provisions of this Statement over the fair value of the original award immediately before its terms are modified, measured based on the share price and other pertinent factors at that date. … b. Total recognized compensation cost for an equity award shall at least equal the fair value of the award at the grant date unless at the date of the modification the performance or service conditions of the original award are not expected to be satisfied. Thus, the total compensation cost measured at the date of a modification shall be (1) the portion of the grant-date fair value of the original award for which the requisite service is expected to be rendered (or has already been rendered) at that date plus (2) the incremental cost resulting from the modification.
But then the examples in ASC 718-20-55-111 through ASC 718-20-55-118 go on to delineate four, count them four, different types of vesting modifications, with two different treatments:
Type I: Probable to Probable: Recognize fair value of original award + incremental expense, if any.
Type II: Probable to Improbable: Recognize fair value of original award + incremental expense, if any.
Type III: Improbable to Probable: New fair value only. Reverse expense for any unvested shares.
Type IV: Improbable to Improbable: New fair value only. Reverse expense for any unvested shares.
Type II and Type IV are incredibly uncommon, but we DO see a good number of Type I and Type III. Type I are often triggered by option exchanges, or any modification to already vested shares, like an extension of exercise grace period at termination. Type III modifications are also quite common at the time of termination when unvested shares are accelerated.
How do you handle the modifications? First, decide if they are Type I or Type III. If the shares are vested, chances are good you are dealing with a Type I. If the shares would have been cancelled if not for the termination, then chances are good you have a Type III. If a Type I, perform two fair value calculations: one before the change, and one after, and compare the expense to determine your incremental expense. If a Type III, you need only one fair value calculation, using the attributes of the grant after the modification. Calculate how much expense has already been booked for the unvested shares in the grant and true up (or down) to the new fair value.
There is good news about most modifications, especially those at the time of termination: they are generally fairly simple one-time calculations where all the expense is booked immediately. Once and done. The bad news is that most systems have limited support for modification accounting and the inputs can be quite tricky. What is the expected term of an underwater option before it is exchanged for a new option? Is it the remaining expected term from the original grant date fair value? The remaining contractual life? An expected term calculated by a Monte Carlo simulation? Each company must decide for itself. A few examples in the standard seem to point to remaining contractual term, but the Monte Carlo simulation approach seems to fly past audit as well. No two audit firms, or audit partners, seem to have the same opinions.
Join me and my talented co-panelists in New Orleans as we wrestle modification accounting to the ground and give you a solid understanding of the required treatment and some varying interpretations. Laissez Les Bon Temps Roulez!
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Joseph Purdy of Solium Transcentive, who will lead the session “Risky Business: Ten Ways to Protect Your Equity Programs.”
Life is full of risks; it is what makes life so interesting. It is how you navigate through the tidal wave of challenges that these risks pose that measure the quality of your success. Well, like everything in life, equity compensation plans involve many different types of risks. As an issuer’s plan administrator, you are responsible for understanding those risks and taking any action possible to mitigate them. It is a daily game of covering your…assets. This includes protecting your job, your reputation, your company, your executives, your shareholders and your most valuable resources–your employees.
Though I have spoken at many conferences, including several local NASPP chapter events, this is my first time on the “big stage” at the national conference. I am very excited to present with a great and diverse panel with years of experience in plan administrative services along with in-house administration, education, compliance, tax and legal services. I have the honor and privilege to present with Emily Cervino of Fidelity Investments, Renee Deming of Cooley and Lori Brennan of UBS Financial Services.
When putting this panel together we wanted to make sure the audience would walk away with a list of suggested procedures to verify or put in place to help mitigate risk. We wanted to ensure this wasn’t like other risk-based sessions we’ve seen over the years that simply scared you with the consequences of risk but really didn’t talk about how you can help mitigate the risks. Our topics will range from grant issuance to taxation and data flow to communication. We’ll also discuss some differences between in-house administration versus plan outsourcing scenarios with a strong emphasis that outsourcing your plan does not diminish your responsibilities for oversight and risk mitigation.
An interesting thing happened on the way to submitting our slide deck to the NASPP. We too ran into a risk situation due to the content of our presentation. The risk was identified by an internal process established by one of the firms represented on this panel. Since our presentation title includes the name “Risky Business” we couldn’t resist putting some pictures from a certain famous ’80’s movie into our slide deck. We were sad when we were told our presentation would create a copyright risk and all the pictures had to be removed. At the same time, it reminded us that risk review policies like this are imperative. This means our funny pictures of Joel, Lana, Barry and even Guido have been replaced with boring pictures of dice–sorry.
Make sure you join us for what should be a very interesting and informative panel. “Risky Business: Ten Ways to Protect Your Equity Programs” is session 4.2 on Tuesday October 9. See you there!
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Jon Doyle of International Law Solutions, who will lead the session “The Amazing Race–Revisiting Global ESPPs.”
Companies are increasingly revisiting global ESPPs. Whether your company has offered its ESPP globally for years, is considering starting or re-starting an ESPP, or expanding your existing ESPP into new countries, this session is for you. The panel will take an in-depth look at global ESPPs.
Increasingly, with complex and expensive regulatory obstacles, as well as low participation in some cases, companies are more selective in offering their ESPPs around the world. In addition, companies that may have suspended their ESPPs internationally due to compliance, participation and budgetary concerns, are increasingly exploring offering their ESPPs in new markets. The panel will discuss the importance of setting expectations on participation and educating executives and local management about global ESPPs.
We will examine the regulatory challenges of a global ESPP, including the unique issues presented by Section 423 plans and how a non-423 component may be of use to you. We will discuss balancing the goal of offering an ESPP broadly while staying compliant. We will explore how to navigate through compliance and administrative roadblocks, as well as the impact of a company’s corporate structure on these plans. The panelists will share their experiences and best practices for successfully offering ESPPs globally.
Don’t miss this session, “The Amazing Race–Revisiting Global ESPPs,” presented by Jon Doyle of International Law Solutions, Bob Hartley of BMC Software, Wendy Jennings of Riverbed Technology, and Kate Lloyd of Accenture at the 20th Annual NASPP Conference in New Orleans, October 8-11.
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Marlene Zobayan of Rutlen Associates, who will lead the session “Keeping Up With The Updates.”
When I first started in the global equity field over 15 years ago, we would prepare specific reports for companies wishing to offer equity globally. For each client, we would send their plan to a local expert in each country who would write a report on the tax and legal consequences of that plan. The overall report would be compiled by a US representative who managed the relationship with the client and talked the client through the findings. In a field that was new to most, this process a good path to follow. It was a surprise to most companies that not all countries followed the same logic as the U.S. when taxing equity compensation.
However, as time went on, the information became more readily available and the level of knowledge among industry members grew. It is no longer ‘news’ to anyone that Australia taxes stock options at vest or that the employer can save money through a French qualifying plan. In fact most of this information is now readily available on the web. However, now we have the opposite issue–the information available is overwhelming, confusing to the layperson and oftentimes contradictory. Additionally, the underlying laws seem to change at an unprecedented rate, for example the first quarter of 2012 there were at least 24 updates of new and pending legislation impacting global equity awards.
Information Overload?
Many accounting, consulting and law firms distribute newsletters to clients and friends whenever there is a change in the international laws impacting equity awards. While a useful tool, and often extremely well written and informative, the net result is that many companies get inundated with similar newsletters from different sources. There is little time to read and understand them all.
Regardless with the rapid pace of international developments all global companies must make the time and effort to keep up to date otherwise they can quickly find their practices and processes out of date and non-compliant.
A Free Resource for NASPP Members
In the NASPP Conference session “Keeping Up With The Updates“, the panel will review the wealth of information available on the NASPP’s Global Stock Plans Portal. These include the alerts which notify companies of updates and the Country Guides, all organized in a searchable archive by country. These resources provide a good foundation for an administrator whose company is expanding into a new country, extending a new type of plan or who simply wants to stay up to date. Although the NASPP global portal is a great resource to educate yourself, it is not a substitute for professional advice. The panel will help companies understand how to identify when the free resources are insufficient, and technical expertise is needed. Finally, the panel will cover some recent updates with a surprise guest.
How many other sessions can help keep your company out of trouble, save you money and provide a surprise guest too?
This week, we feature another installment in our series of guest blog entries by NASPP Conference speakers. Today’s entry is written by Narendra Acharya of Baker & McKenzie, who will lead the session “50 Ways to Pay (and Tax) Your Board of Directors.”
While Board director compensation does not receive the same level of media focus as executive compensation, it does not escape scrutiny (see “Companies With the Highest-Paid Boards of Directors,” The Bottom Line, June 15, 2012). Earlier this year, director compensation was also the subject of a recent unsuccessful shareholder proposal to expand Say-on-Pay to director compensation (see Proposal 5 in Apple’s 2012 proxy statement).
At the same time, director compensation varies across companies to a greater degree than executive compensation practices and is more likely to be more influenced by the company’s historical practice than the company’s executive compensation practices. As a result, there can be substantially greater differences in the structure of director compensation than executive compensation, even within the same industries. Director compensation correlates more with company size than with industry (see “Annual Survey Reveals Emergence of New Compensation Practices,” The Conference Board, November 2, 2011.) These differences in the structure include different vesting practices as well as the availability of deferral elections.
Even when director grants are made under the same equity compensation plan that is used for employee awards, the process and procedures for implementing grants often is quite separate from the employee grant procedures and the grants may be administered by a group that does not generally administer employee awards.
As the makeup of boards becomes more international–recent surveys indicates that up to 10% of non-employees directors are not U.S. nationals–more companies need to address the specific US tax requirements that apply when non-employee directors are a US nonresident alien for income tax purposes. In the absence of specific tax treaty relief, companies can be required to withhold at a flat 30% rate on all of the director compensation paid to US nonresident alien directors. This can be a surprising result–in contrast to the treatment of compensation paid to US citizen/resident directors.
At the 20th Annual NASPP Conference, the session “50 Ways to Pay (and Tax) Your Board of Directors” will provide a multi-disciplinary review of trends in pay practices for directors. The session will also provide an overview of the US tax consequences of directors’ compensation including the use of stock and deferral programs. Finally, the session will address the unique US tax issues related to directors that are not residents of the United States for income tax purposes.
Emily Cervino is a Vice President at Fidelity Stock Plan Services. She has been an active participant in the equity compensation industry since 1998, and now focuses on strategic marketing initiatives, thought leadership, and building Fidelity’s strong industry presence.