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|Text of IRS Rev. Rul. 2005-39 on Treatment of 83(b) Restricted Stock for Golden Parachute Purposes (PDF)|
Internal Revenue Service [IRS]
June 16, 2005
Holdings: Restricted stock for which a section 83(b) election has been made is treated as outstanding stock for purposes of determining whether there has been a change in ownership or control under section 280G. In addition, restricted stock for which a section 83(b) election has been made is treated as outstanding stock for purposes of determining the amount of stock held by shareholder in testing whether such shareholder is a disqualified individual under section 280G.
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