• Type: Publication series
  • Date: 6/5/2012

United States – Proposed Regs on Property Transferred Tied to Performance of Services  

The U.S. Internal Revenue Service (IRS) has issued proposed regulations that may impact taxpayers who receive property transferred in connection with the performance of services, such as restricted stock and shares transferred on the exercise of stock options.  The IRS and Treasury indicate that some confusion has arisen regarding conditions that may give rise to a "substantial risk of forfeiture," which impacts when an employee must include the value of such property in income.  The proposed regulations help to clarify when a substantial risk of forfeiture exists in relation to certain conditions.


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