---
title: "Map the income timing for property transferred for services"
url: "https://ailawframework.com/practice/taxation/map-taxing-points-for-an-employee-share-or-option-plan/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A26-T1-R14-US"
practice_area: "Taxation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Map the income timing for property transferred for services

> Build a table of the property, the amount paid, the transfer date, and the facts in the papers about whether the rights are transferable or are conditioned on future services.…

Canonical page: https://ailawframework.com/practice/taxation/map-taxing-points-for-an-employee-share-or-option-plan/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Taxation](https://ailawframework.com/practice/taxation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | Build a table of the property, the amount paid, the transfer date, and the facts in the papers about whether the rights are transferable or are conditioned on future services. Do not compute the income and do not prepare an election. |
| What the lawyer must review | 26 U.S.C. § 83: if property is transferred in connection with the performance of services, the excess of its fair market value, determined without regard to any restriction other than a restriction which by its terms will never lapse, at the first time the rights are transferable or are not subject to a substantial risk of forfeiture, over the amount paid, is included in the income of the person who performed the services in that year. Rights are subject to a substantial risk of forfeiture if the right to full enjoyment is conditioned upon the future performance of substantial services by any individual. Rights are transferable only if the rights of a transferee are not subject to a substantial risk of forfeiture. You decide whether the section applies. Do not treat this section as the rule for nonqualified deferred compensation or for a statutory option. Those are other sections, which you open. Do not state an election deadline. |
| Written for | United States |
| Applies to | [Map taxing points for an employee share or option plan](https://ailawframework.com/practice/taxation/map-taxing-points-for-an-employee-share-or-option-plan.md) |

## Checking plan

- What the AI does: Build a table of the property, the amount paid, the transfer date, and the facts in the papers about whether the rights are transferable or are conditioned on future services. Do not compute the income and do not prepare an election.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- The table records the facts. It does not compute the inclusion.
- An election under this section has its own conditions. Do not state a deadline that has not been read in the section.

## Sources

- [26 U.S.C. § 83 (property transferred in connection with performance of services)](https://www.law.cornell.edu/uscode/text/26/83) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

## Forms and precedents for this task

| Form or precedent | Kind | AI level | Summary |
| --- | --- | --- | --- |
| [Employee share scheme deferred taxing point checklist](https://ailawframework.com/precedents/taxation/ess-deferred-taxing-point.md) | Checklist | Yellow | The deferred taxing points and the 30-day rule on the Australian Taxation Office tax-deferred schemes page, for shares and rights, including the end of cessation of employment as a taxing point from… |

Signed-in accounts can read the full text of each one.

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*