IRC Section 83(b)

News & Analysis as of

IRS Issues Final Regulations on Property Transferred for Services Under Section 83

The Treasury Department (Treasury) and Internal Revenue Service (IRS) have issued final regulations clarifying the forfeiture provisions under Section 83 of the Internal Revenue Code of 1986, as amended, for transactions...more

IRS Clarifies Position On Substantial Risk Of Forfeiture In Final Section 83 Rules

The IRS issued final regulations regarding the definition of “substantial risk of forfeiture” under Code Section 83. These regulations have a particular impact on the timing of taxation of employer transfers of stock and...more

Selecting the Right Employee Incentive Plan Can Be Tricky

The purpose of an employee incentive plan, regardless of the specific type or form that it takes, is to more closely align a key employee’s financial interests with the company’s. The company owners’ challenge when developing...more

Final Regulations Illustrate That Lock-Up Arrangements Do Not Prevent Current Taxation Under Section 83

A transfer restriction on its own is not sufficient to defer tax on a compensatory equity grant. This proposition is highlighted by final regulations issued by the IRS on Feb. 25th under Internal Revenue Code section 83. The...more

IRS Issues Final Regulations under Internal Revenue Code Section 83 Regarding Substantial Risk of Forfeiture Analysis

Companies that compensate their employees with annual or long-term awards of restricted property such as restricted stock grants should take note of the final regulations relating to property transferred in connection with...more

Tax Court Ruling Impacts the Treatment of Income Allocations Attributable to Unvested Partnership Capital Interests

The United States Tax Court recently issued its opinion in Crescent Holdings, LLC v. Commissioner, 141 T.C. No. 15 (12/2/13), a ruling regarding allocations of income attributable to an unvested partnership interest. The...more

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