Under Internal Revenue Code section 83(b), taxpayers who receive property, such as stock, in exchange for services that is subject to forfeiture, or is unvested for a certain period, may elect to pay income tax on the fair market value of the property as if it were not subject to forfeiture, or fully vested, in
Section 83(i) Guidance Welcomed But Creates Even More Complexity
The IRS issued Notice 2018-97 (Notice) on December 7, 2018, providing some much needed guidance on interpreting Internal Revenue Code (Code) section 83(i) for qualified equity grants. Section 83(i) was added to the Code as part of the 2017 Tax Cuts and Jobs Act effective at the beginning of this year and permits employees granted
A More Detailed Look At Section 83(i) Plans
Last February I blogged about new Section 83(i) of the Internal Revenue Code that was added by the 2017 tax reform legislation and provides for up to
New Section 83(i) Provides a New Tool for Allowing Employees to Participate in the Sale of their Private Corporation-Employer
Employers often tell me how they want to provide their employees who have helped them build their business an opportunity to benefit from a future sale of the business. In the past, I have then discussed with them the pros and cons of such techniques as restricted stock, phantom stock, and stock appreciation rights, including