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The document discusses recent final Treasury regulations and a Tax Court case that clarify the definition of 'substantial risk of forfeiture' under IRC Section 83, which affects when employees must report income from property transferred by employers. It emphasizes that substantial risk can only be established through specific service or performance conditions, and outlines key clarifications regarding transfer restrictions and the circumstances under which risks of forfeiture are considered substantial. The relevance of these clarifications for AALU members in relation to tax implications on insurance policies and nonqualified deferred compensation arrangements is also highlighted.

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