Extract to table

For federal income tax purposes, Section 1032 of the Code provides that "[n]o gain or loss shall be recognized to a corporation on the receipt of money or other property in exchange for stock (including treasury stock) of such corporation

For employees who performed services in Massachusetts during all or a portion of the stock option vesting period (the period from the grant date to the vesting date, or from the grant date to the exercise date, depending on the state's allocation methodology), the equity compensation income must be sourced to Massachusetts based on the ratio of the employee's Massachusetts workdays to total workdays during the applicable vesting or service period

This allocation must be performed on a grant-by-grant basis, as the relevant service period may differ for each grant

Upon exercise, the gain must be allocated among the states in which the employee performed services during the vesting period, based on each state's workday allocation rules