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Final Substantial-Risk-of-Forfeiture Rules Are Released
Journal of Accountancy Link to more items from this source
Feb. 26, 2014
"The new regulations clarify that [1] a substantial risk of forfeiture may be established only through a service condition or a condition related to the purpose of the transfer; [2] in determining whether a substantial risk of forfeiture exists based on a condition related to the purpose of the transfer, both the likelihood that the forfeiture event will occur and the likelihood that the forfeiture will be enforced must be considered; and [3] except as specifically provided in Sec. 83(c)(3) and Regs. Secs. 1.83-3(j) ... and 1.83-3(k) ... transfer restrictions do not create a substantial risk of forfeiture."

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