In startups and early-stage companies, founders often receive restricted equity grants as compensation for their services. With some planning, founders can potentially lower the taxes they pay on the appreciation of the...more
For the first time, the IRS has issued an official form to be used for making an election under Section 83(b) of the Internal Revenue Code. Until the IRS issued Form 15620 in late 2024, taxpayers used their own “homemade”...more
Our Federal Tax Group explains the new standardized Form 15620 that taxpayers can use when receiving property that is subject to a “substantial risk of forfeiture.”...more
As part of US tax planning for founders, employees, board members, and other individual service providers who receive equity that is subject to vesting in connection with their services, Section 83(b) elections are frequently...more
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
As explained in a prior blog post, an employee who timely files a Section 83(b) election will be taxed on the fair market value of property transferred (typically restricted stock) to him or her in exchange for services on...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
Many people are forming start-up entities, especially in the Boston and Worcester areas, and for some, it becomes a great success story. For others, it does not. As an attorney who assists many start-ups and investors, I see...more
Update: on April 15, 2021, the Internal Revenue Service announced that it would temporarily (through December 31, 2021) allow Section 83(b) elections to be signed digitally or electronically, instead of requiring handwritten...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
In response to the COVID-19 pandemic, the IRS recently issued Notice 2020-23 to extend the deadline to July 15, 2020, for any Internal Revenue Code Section 83(b) election that would otherwise have been due on or after April...more
The Tax Cuts and Jobs Act includes a new provision that can delay the taxation of compensation paid to employees of “eligible corporations” in the form of “qualified stock” for up to five years. The provision is set forth in...more
Contractors, advisers, and employees (collectively, “Service Providers”) who receive property that is non-transferrable or subject to a substantial risk of forfeiture must generally defer their income recognition until those...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
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
On the TV show Futurama, the aged proprietor of the delivery company Planet Express, Professor Hubert J. Farnsworth, had a habit of entering a room where the other characters were gathered and sharing his trademark line,...more