Final Regulations Issued for Substantial Risk of Forfeiture Under IRC Section 83

Share Button

The IRS recently issued final regulations clarifying the meaning of substantial risk of forfeiture under Section 83 of the Internal Revenue Code. For the most part, the final regulations are consistent with past regulations and interpretations. However, the clarification eliminates some of the previous “wiggle room” in the regulations, thereby making it harder to defer tax. The regulations apply to any property transferred on or after January 1, 2013.

Previously, under Regs. Sec. 1.83-3(c)(1), “a substantial risk of forfeiture exists where rights in property that are transferred are conditioned, directly or indirectly, upon the future performance (or refraining from performance) of …read more

Read more here: Technology

About Aronson LLC

Aronson LLC has written 574 post in this blog.

Aronson LLC has been thinking ahead for its clients for more than 50 years. Aronson’s construction, real estate, government contracting, nonprofit, technology and private industry experts provide innovative audit, tax, and consulting services that help its clients move to the next level. From start-up to exit strategy, Aronson works with companies throughout the entire business lifecycle by proactively identifying opportunities and addressing challenges so that clients are able to focus on their core business. Aronson shows companies how to rethink everything to be more profitable, more competitive and better prepared for the future.

Share Button