Amends the Internal Revenue Code to exclude from the gross income of an employee: (1) shares of employer securities received in a qualified employee stock distribution as compensation for services that do not exceed the lowest number of employer securities received by any employee in such distribution; (2) any gain on such securities if held by an employee for not less than 10 years; and (3) in the case of any qualified disposition of an employer security that meets such 10-year holding requirement, any gain on so much stock acquired during the 60-day period beginning on the date of such disposition as does not exceed the fair market value of the employer security so disposed.
Allows employers a tax deduction for the fair market value of securities transferred in a stock distribution. Requires an employee to recapture in gross income the amount of employer securities excluded from gross income if such securities are disposed of within five years after receipt.