IRC Section 83(b) Election for Restricted Property: Making the Election, Advantages and Risks
Recording of a 110-minute CPE webinar with Q&A
This webinar will outline the advantages and risks of making an IRC Section 83(b) election. Our panel of federal income taxation professionals will point out scenarios when the election is advantageous, the caveats of making the election that a service provider must consider and review the steps for submitting the election.
Outline
- IRC Section 83(b): Introduction
- Eligibility
- Taxation of restricted property
- Company considerations
- Service provider considerations
- S corporation considerations
- Profits interests; protective Section 83(b) elections
- Missed elections
- Examples
Benefits
The panel will cover these and other critical issues:
- When is it beneficial to file a Section 83(b) election?
- When is it not advantageous to file a Section 83(b) election?
- How is the tax calculated when restricted property is granted, and a Section 83(b) election is in place? What are the tax consequences upon vesting?
- How is the tax calculated upon vesting of restricted property where a Section 83(b) election is not in place?
- How is a missed Section 83(b) election rectified?
Faculty
David A. Gilbert
Of Counsel
Blank Rome
Mr. Gilbert concentrates his practice in the area of business tax law. He represents domestic and international clients... | Read More
Mr. Gilbert concentrates his practice in the area of business tax law. He represents domestic and international clients in a wide range of federal, state, and local tax matters. Mr. Gilbert advises publicly traded and private corporations, partnerships, funds, tax-exempt organizations, and individuals on various matters, including those arising in taxable and tax-free mergers and acquisitions, divestitures, restructurings, spin-offs, redemptions, and liquidations; inbound and outbound investments; formation, operation, and acquisition of limited liability companies, partnerships, and Subchapter S corporations; real estate transactions; financings; and tax controversies. He also has experience advising private equity and hedge fund sponsors on the tax aspects of fund formation as well as representing institutional investors regarding joint ventures and other investments. Mr. Gilbert is admitted to practice in New York and Florida, and is also a certified public accountant in New York. He earned his LL.M. in Taxation from New York University School of Law and his J.D. from the University of Alabama School of Law. Mr. Gilbert also received his M.S. in Accounting from the University of Florida and his B.S. in Accounting and Finance from Florida State University.
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TJ Wilkinson
Shareholder
Shulman Rogers
Mr. Wilkinson provides clients with insight into the income tax implications of their business transactions and helps... | Read More
Mr. Wilkinson provides clients with insight into the income tax implications of their business transactions and helps them to come up with tax-efficient, tax-compliant structures that maximize value while minimizing tax risk. He advises on matters relating to mergers, acquisitions, distributions, entity formation, qualified small business stock (Section 1202), private equity investments, capital structure, loans, equity compensation plans (including Section 409A compliance and risk), and implications of new legislation and guidance. Mr. wilkinson earned degrees from Harvard University (A.B.), Columbia Law School (J.D.) and New York University School of Law (LL.M.). He is an active member of the American Bar Association.
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