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Section 83 and the 'Substantial Risk of Forfeiture'
Winston & Strawn LLP Link to more items from this source
Mar. 3, 2014
"IRS took pains to emphasize that it did not intend the new regulations to change the law only to clarify it. Indeed, the new regulations mostly state settled law and common understanding.... The regulations reemphasize the IRS' long-held position that a provision or clause that may result in forfeiture of property transferred to an individual must be sufficiently likely to actually result in forfeiture in order to prevent taxation of the property upon transfer (or vesting)."

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