FIFO Rules across APSS, RSU and ESPP schemes
HI, I work for a company which provides access to all of these schare scheme types. I have read on a number of threads about teh FIFO rules but I wanted to clarify if the FIFO rules put all shares aquired under these different scchemes into ONE pot or are the APSS schemes treated as a seperate pot. Secondly how to handle the 30 day rule across these scheme. I have put an example together and would appreciate expert views
many thanks
Shares Table
Source | Date Rec'd | Quantity | Price Per Share | Total |
Private Purchase | 01/01/2024 | 10 | €50.00 | €500.00 |
ESPP | 01/03/2024 | 20 | €60.00 | €1,200.00 |
RSU | 01/06/2024 | 30 | €70.00 | €2,100.00 |
APSS* | 01/09/2024 | 40 | €80.00 | €3,200.00 |
APSS shares were appropriated on 31/08/2021 and released after 3 years on 01/09/2024.
Queries:
a) Are all 4 purchase types grouped together for FIFO rules once received and the beneficiary is entitled to sell them?
b) Clarification on when the APSS shares should be considered within the broader FIFO pool:
- Is the FIFO date for these shares:
- 01/09/2024 (the 3-year release date), OR
- 01/09/2023 (two years after the appropriation date, when the shares could have been transferred or sold, despite tax implications)?
c) Regarding the
4-week rule:
- If 10 shares are sold on 10th March 2024, which of the following statements is correct?
- The 4-week rule applies, so the base cost is ESPPs purchased on 1st March.
- The 4-week rule does not apply as 10 shares sold do not match the same quantity of 20 shares purchased on 1st March.
- In another scenario if 30 shares are sold on 10th of March do 20 shares get 1st of march cost basis of $60 and the other 10 get the 1st Jan cost basis of $50 - thereby what was purchased in the 4 weeks does not apply FIFO rules but other additional shares do?