Taxation of Compensatory Transfers of Property (IRC § 83)

Summary

This practice note addresses the taxation of compensatory transfers of property under Section 83 of the Internal Revenue Code (Section 83). With certain exceptions, Section 83 governs the timing for when a service provider must include in income property transferred to that service provider in connection with the service provider's performance of services. It includes a discussion of certain elections under Section 83 that a service provider may make in order to accelerate or defer taxation of such compensatory property.