Final IRC Section 83 Regulations Make it Harder to Defer Tax on Compensatory Stock Transfers

The IRS has issued final regulations under Internal Revenue Code Section 83 that will make it more difficult for taxpayers who receive stock in connection with the performance of services to defer tax on the value of the stock received. The IRS has accomplished this by clarifying and tightening certain rules relating to whether a taxpayer’s rights to property are subject to substantial risk of forfeiture. This article, published in Forbes, does a nice job explaining these new regulations.