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IRS Regs Clarify When Property Is Subject to Substantial Risk of Forfeiture
Stinson Link to more items from this source
[Guidance Overview]
Mar. 2, 2014
"Not only must the service provider's property interest be subject to a service condition or condition related to the purpose of the transfer for the property interest to be subject to a substantial risk of forfeiture, but the facts and circumstances at the time of the property transfer must establish the likelihood that the condition leading to forfeiture will occur, and that the service recipient is likely to enforce the forfeiture."

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