Contract analysis

1. To the Internal Revenue Service — The original executed Election statement is enclosed with this transmittal letter and is being filed with the Internal Revenue Service at the Service Center identified above. This filing is being made via United States Certified Mail, Return Receipt Requested, to establish proof of timely filing. This copy constitutes the official filing of the Election for purposes of Section 83(

2. To the Transferor Entity — A copy of the executed Election statement must be delivered promptly to the person or entity for whom the services giving rise to the transfer of the Property were performed, or the transferor of the Property if different. The copy should be delivered to: [Insert name and address of the entity that transferred the property, e.g., the LLC or partnership]. Delivery may be made by hand deli

3. To the Taxpayer's Personal Federal Income Tax Return — A copy of the executed Election statement must be attached to the taxpayer's federal income tax return (Form 1040 or applicable form) for the taxable year in which the transfer of the Property occurred, in accordance with Treasury Regulations Section 1.83-2(c). The taxpayer should retain a copy specifically designated for this purpose and should provide the co

4. To the Taxpayer's Personal Records — A copy of the executed Election statement should be retained in the taxpayer's permanent personal files, together with all proof of mailing (including the USPS certified mail receipt, the return receipt green card, and, when received, the IRS date-stamped copy of the Election). These records should be maintained indefinitely, as the Internal Revenue Service may inquire about th

1. Original executed Section 83(b) Election Statement

2. Duplicate copy of Section 83(b) Election Statement (for IRS date-stamp and return)

3. Self-addressed, stamped return envelope cc: [Insert Name of Electing Taxpayer] (via [email / hand delivery]) [Insert Name and Address of Transferor Entity — for entity copy delivery] [Insert Name of Taxpayer's Personal Tax Advisor, if applicable] Calderwood & Harkness LLP file — Matter No. [Insert] APPENDIX: INSTRUCTIONS FOR USE OF THIS TEMPLATE Internal Guidance Page — NOT To Be Included in the Mailed Letter This

1. Retain USPS certified mail receipt and return receipt (green card). The certified mail receipt (USPS Form 3800) should be retained immediately upon mailing. The return receipt (PS Form 3811, the green card) will be returned to the sender by the United States Postal Service after the package is delivered to the IRS Service Center. Both documents should be filed with the taxpayer's permanent records and copied for r

2. Upon receipt of IRS date-stamped copy, file with taxpayer's permanent records. If the IRS returns the date-stamped duplicate copy of the Election statement, it should be forwarded to the taxpayer for retention in the taxpayer's permanent files. If the date-stamped copy is returned to Calderwood & Harkness LLP, the firm should promptly forward it to the taxpayer and retain a copy in the matter file. Note that the I

3. Confirm with transferor entity that its copy has been received. The responsible attorney or paralegal should follow up with the transferor entity (or its counsel) to confirm that the entity has received its copy of the executed Election statement. This confirmation should be documented in the matter file.

4. Remind taxpayer to attach a copy of the Election to their Form 1040 for the taxable year of the transfer. The responsible attorney should communicate to the taxpayer (and the taxpayer's personal tax advisor, if applicable) that a copy of the Election statement must be attached to the taxpayer's federal income tax return for the taxable year in which the property transfer occurred. This communication should be made

5. Calendar a follow-up reminder. The responsible attorney should calendar a follow-up reminder for the tax filing season following the year of the property transfer to confirm that the taxpayer (or the taxpayer's personal tax advisor) has attached a copy of the Election to the taxpayer's filed return. END OF TEMPLATE — APPENDIX PAGE(S) TO BE REMOVED BEFORE MAILING Field | Entry Full Legal Name of Taxpayer | [Insert]