Yuval Navot (Elieser Kaplan Law Offices, Tel Aviv) presents Taxation of Compensatory Stock Options Under Tax Treaties, 126 Tax Notes 325 (Jan. 18, 2010), at Hebrew University Law School as part of its Tax Law & Policy Colloquium. Here is the abstract:

Tax treaties may not provide adequate protection against double taxation and double nontaxation of service providers’ income from compensatory stock options. This report identifies the elements allowing such double taxation and double nontaxation to arise and analyzes the various theoretical approaches to address this problem. It then describes and evaluates the approach adopted under the OECD model treaty, as well as the approach adopted under all three U.S. treaties that contain arrangements regarding compensatory stock options.