June 14, 2012
IRS Proposes Section 83 Guidance
– Broc Romanek, CompensationStandards.com
As noted in this blog from Bill Tysse, the IRS recently proposed new regulations under Section 83 of the Internal Revenue Code that would consolidate the IRS’s position from an earlier Revenue Ruling (Rev. Rul. 2005-48) and, in effect, cabin-in a First Circuit Court of Appeals decision (Robinson v. Commissioner) handed down over 25 years ago to its specific facts. Here are a few firm memos on the new proposal.
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