Good news – the IRS announced that it will allow taxpayers to make and file Section 83(b) elections with a digital signature. This decision makes permanent a practice that the IRS temporarily allowed during the COVID-19...more
On May 22, 2020, the IRS released an Office of Chief Counsel Memorandum (the Memo) that addresses (i) when income inclusion and the withholding of FICA and federal income taxes apply to stock-settled awards and (ii) the...more
On August 21, 2018, Treasury and IRS released Notice 2018-68, their initial guidance on the application of Code section 162(m) after Tax Reform (including the operation of the grandfather provision for compensation required...more
If an individual makes a Section 83(b) election to include in income the value of unvested property (such as restricted stock) that is transferred in connection with the performance of services, the individual must file the...more
On June 22, 2016, the IRS issued long-awaited proposed regulations on Section 457(f) plans, as well as additional proposed regulations under Section 409A. ...more