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Rev. Rul. 2007-49: Transfers of Section 83 Stock in Reorganizations and Taxable Stock Acquisitions (PDF)
Internal Revenue Service [IRS] 
[Official Guidance] July 6, 2007
10 pages. Excerpt: 1) There is not a transfer of substantially nonvested stock subject to § 83 where restrictions imposed on substantially vested stock cause the substantially vested stock to become substantially nonvested. 2) There is a transfer of substantially nonvested stock subject to § 83 where a service provider exchanges substantially vested stock for substantially nonvested stock in a reorganization described in § 368(a). 3) There is a transfer of substantially nonvested stock subject to § 83 where a service provider exchanges substantially vested stock for substantially nonvested stock in a taxable stock acquisition.
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