No CRS summary available for this bill.
This section establishes a reduced rate of tax under section 11(b) of 3 percentage points below the otherwise applicable rate for any qualifying SHARE corporation (i.e., a U.S.-domiciled corporation with an average of 500 or more full-time U.S. resident employees), subject to an aggregate cap equal to the market value of stock granted under a SHARE plan. A SHARE corporation must demonstrate a SHARE ratio of at least 5% (i.e., aggregate prior grants of common stock to employees under a SHARE plan, excluding incentive equity and certain forfeited stock, divided by total outstanding common stock) or distributions of at least 1% of outstanding common stock under a SHARE plan in the taxable year; non-publicly traded corporations must also provide fair market valuations and liquidation opportunities. A SHARE plan requires periodic common stock distributions to participating employees, including the lowest-compensated 80% of eligible employees, with a safe harbor for per-employee caps of $250,000 (adjusted annually after 2025 for wage growth).
This section establishes a new exclusion from gross income for SHARE plan stock (i.e., stock received by an employee under a SHARE plan, as defined in section 12 of this Act). The exclusion applies to stock received after the date of enactment.