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Is the first day of the offering period always the same as the "grant date" in the context of employee stock purchase plans (ESPP) in the United States?


Motivation to ask the question:

I'm asking as I read on https://blog.wealthfront.com/good-espp-no-brainer (mirror) :

Unlike a 401(k), your contributions to the ESPP are taxed at ordinary income rates. If you hold your shares for more than a year after the purchase date AND more than two years after the beginning of the offering period then any profit above the gain from the discount will be taxed at [long-term] capital gains tax rates.

but the financial institution (namely, E-Trade) that manages the ESPP I am looking at only displays the "grant date" in their ESPP section (https://us.etrade.com/etx/sp/stockplan/#/holdings) and doesn't mention any first day of the offering period , from what I can see. The answer to the question would be useful to make sure to wait two years after the beginning of the offering period so that any gain is taxed at capital gains tax rates.


Screenshot from https://us.etrade.com/etx/sp/stockplan/#/holdings:

enter image description here


I have crossposted the question at:

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    Very timely question, as I was just wondering the same thing – InbetweenWeekends Jan 27 at 3:31
  • Does your employer maintain any kind of ESPP records in addition to E-Trade? – Craig W Jan 27 at 16:13
  • Also, your E-Trade link requires you to log in, and is specific to you anyway. If it's important maybe you could take a screenshot and redact any personal or extraneous information? – Craig W Jan 27 at 16:14
  • @CraigW thanks, most likely the company has the information, but I'd prefer to get the information directly from E-Trade (I may be given erroneous information when asking someone in the company). I think the link is the same for any E-Trade account holder with ESPP. I'll include a screenshot once on computer. – Franck Dernoncourt Jan 27 at 16:18
  • If your company reports the beginning of the offering period as the same as the grant date that E-Trade shows, that would be sufficient, right? – Craig W Jan 27 at 16:20
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Answer from https://fairmark.com/compensation-stock-options/employee-stock-purchase-plans/dispositions-of-espp-stock/:

For this purpose, the grant date is normally the beginning of the offering period. Tax regulations issued in 2009 specify that in some situations the end of the offering period (when you purchase the shares) will be considered the grant date. Your company should inform you if this is the case.

Follow-up question: In what case(s) the end of the offering period (when one purchases the shares) is considered the grant date?

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