On November 7, 2024, the IRS released Form 15620, which can be used by taxpayers to file Section 83(b) elections in connection with transfers of property that are subject to a substantial risk of forfeiture when transferred...more
On November 7, 2024, the IRS introduced Form 15620, a new standardized form for taxpayers opting to make a Section 83(b) election. Previously, taxpayers needed to send a letter to the IRS with the required information to make...more
A Section 83(b) election is a short, generally one-page document you send to the IRS to notify them that you wish to be taxed in connection with property subject to a "substantial risk of forfeiture" (more on this below) that...more
In response to the COVID-19 pandemic, the U.S. Internal Revenue Service (“IRS”) issued Notice 2020-23, 2020-18 IRB 732 (April 27, 2020) (the “Notice”) providing a temporary extension, until July 15, 2020, for Internal Revenue...more
A limited extension, until July 15, 2020, is available for Internal Revenue Code (“Code”) Section 83(b) elections otherwise due on or after April 1, 2020, and before July 15, 2020. It will be especially important for...more
A taxpayer who makes a Section 83(b) election to accelerate the income taxation date of certain transferred property is no longer required to file a copy of the Section 83(b) election with his or her tax return for the year...more
On July 23rd of last year, I blogged on a set of proposed regulations eliminating the requirement that a taxpayer attach a copy of his or her Section 83(b) election to their individual tax return. This July, the IRS made the...more
The IRS adopted final regulations that no longer require taxpayers who have made Internal Revenue Code §83(b) elections to attach a copy of the election to their annual federal income tax return. Under §83, restricted...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
Prior to a recent change, in order for a Section 83(b) election to be effective, the taxpayer had to: - File the Section 83(b) election within 30 days of the receipt of restricted property (typically, restricted stock)...more
On July 25, 2016, in T.D. 9779, the IRS published final regulations concerning the procedures for making an election under section 83(b) of the Code. The new final regulation, Treas. Reg. §1.83-2, eliminates the requirement...more
In an effort to improve e-filing, the IRS has proposed to eliminate the need to file a copy of a Section 83(b) election with the service provider’s annual tax return. Taxpayers receiving non-vested stock or partnership...more