the situation: a private, early stage company, dormant for a few years since incorporation
the client owned 100% of their shares for 2+ years. there was no vesting, and thus no 83(b) election was made at that time.
now, 2 years on, these shares will be subject to repurchase over time (essentially a vesting provision for 4 years).
what are the 83(b)-related issues now? will the client have to pay taxes as the the repurchase right lapses?
thanks!