New Article: Substantial Risk of Forfeiture

An article recently published in the Lexis Practice Advisor, Substantial Risk of Forfeiture, discusses the concept of substantial risk of forfeiture (SRF) under sections 83, 409A, 457(f), 457A, and 3121(v)(2) of the Internal Revenue Code and the different consequences of the failure to achieve a SRF under each such section.

Topics covered are:

• Significance of SRF under the Various I.R.C. Sections
• Definition of SRF
• Conditions that Generally Support the Existence of a SRF and Related Requirements
• Conditions that Generally Do Not Support the Existence of a SRF
• Other rules relating to SRF

It is accompanied by a Substantial Risk of Forfeiture Comparison Chart, which summarizes the rules.