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Stock Option Downward Repricings

Stock Option Downward Repricings

What do you do, when you receive a 409A valuation for your company that is lower than the exercise price of previously granted stock options? A few years ago I read an article titled, We Spend Too Much Time Celebrating “Start Ups” and Not Enough Time...
LLC Conversions

LLC Conversions

So, you’d like to convert your limited liability company, which is taxed as a partnership, into a C corporation? This is generally not hard to do from a pure mechanics perspective.  If your LLC is organized in Delaware, or certain other states, the conversion can be...
Modification of Option Vesting

Modification of Option Vesting

Every year I get a new hard copy set of income tax regulations. These come in four phone book-size volumes. I probably look forward to getting these more than I should—they come at the end of December, and for a tax guy like me it always feels like a belated Christmas...
Do Not Immediately Early-Exercise an ISO

Do Not Immediately Early-Exercise an ISO

Someone just emailed me the following question (paraphrased): “I have a private company client who has approved a new hire grant to their new CEO that includes early exercise. The total exercise price of the option grant is $180,000 and the CEO is planning to...
Future Token Contracts

Future Token Contracts

Let me start with the bad news: I have been persuaded that future token contracts likely do not work. But let’s back up. If your offshore entity[1] has not yet minted tokens but you want to get something into the hands of service providers, historically you have...