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Risk of forfeiture

Tax Court: Stock issued to employee/49.75% owner wasn’t subject to substantial risk of forfeiture

Tax Court: Stock issued to employee/49.75% owner wasn’t subject to substantial risk of forfeiture

QinetiQ U.S. Holdings Inc., TC Memo 2015-123 The Tax Court has held that where a corporation issued 49.75% of its stock to an employee shortly after the formation of the corporation, a successor corporation could not take a compensation deduction with respect to the stock many years later. There was some question as to whether […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney