IRS Proposes Clarifications to Substantial Risk of Forfeiture Definition in Section 83
Author: Michael Gerald.; Robin M. Schachter.; Bruce E. Simonetti .
Source: Volume 30, Number 01, Fall 2012 , pp.63-67(5)
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Abstract:
The Internal Revenue Service has issued proposed regulations that are intended to clarify what constitutes a “substantial risk of forfeiture” for restricted stock and other compensatory restricted property. However, the emphasis of the proposed rules is potentially further reaching than mere clarification, such that substantive implementation may change existing practices and interpretations.Keywords: IRC Section 83; substantial risk of forfeiture; restricted property; restricted stock; property transferred in connection with services
Affiliations:
1: Akin Gump Strauss Hauer & Feld LLP; 2: Akin Gump Strauss Hauer & Feld LLP; 3: Akin Gump Strauss Hauer & Feld LLP.