Internal Revenue Bulletin:  2012-25 

June 18, 2012 


Table of Contents

REG-141075-09 REG-141075-09

Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 of the Code clarify the definition of a substantial risk of forfeiture under regulations section 1.83-3(c)(1). The regulations also update the regulations under section 1.83-3 to incorporate the holdings of Revenue Ruling 2005-48, 2005-2 C.B. 259, which address the substantial risk of forfeiture created by liability under section 16(b) of the Securities Exchange Act of 1934.

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