EMPLOYEE PLANS

REG–141075–09, page 1028. Section 83 addresses the income tax consequences of property transferred in connection with the performance of services. Proposed regulations under section 83 of the Code clarify the definition of a substantial risk of forfeiture under regulations section 1.83–3(c)(1). The regulations also update the regulations under section 1.83–3 to incorporate the holdings of Revenue Ruling 2005–48, 2005–2 C.B. 259, which address the substantial risk of forfeiture created by liability under section 16(b) of the Securities Exchange Act of 1934.