Internal Revenue Bulletin:  2014-12 

March 17, 2014 


Table of Contents

TD 9659T.D. 9659

Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. The final regulations clarify the definition of a substantial risk of forfeiture under § 1.83–3(c)(1). The final regulations also update the regulations under § 1.83–3 to incorporate the holdings in Revenue Ruling 2005–48 (2005–2 CB 259) which address the substantial risk of forfeiture created by liability under Section 16(b) of the Securities Exchange Act of 1934. Rev. Rul. 2005–48 (2005–2 CB 259) is obsolete as of February 26, 2014.

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