Extension of Forfeiture Period

[Brian Haynes]

I have a restricted stock award where an employee will vest in a certain number of shares in a closely held company at the end of this year after sucessfully completing 10 years of service. Assuming the arrangement is not subject to Section 409A, can the forfeiture period be extended by the end of this year for another 7 years under Section 83 without trigerring taxation? Thanks for the help.