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IRS Clarifies Conditions that Constitute a Substantial Risk of Forfeiture Under Section 83

The IRS recently released final regulations (“Final Regulations”) clarifying the conditions that constitute a substantial risk of forfeiture for purposes of Section 83 of the Internal Revenue Code.  As some of you know, Section 83 generally provides that property transferred in connection with the performance of services will be not be taxed until the date […]

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