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Rule 701 and Equity Grants to Foreign Employees

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A private US based company has two equity plans, one for granting options in the US and one for granting warrants in an EU country.  (As I understand it, they grant warrants to comply with local law).


I would think the foreign grants are included in the Rule 701 analysis, but I'm getting a different story from a record keeper and I can't seem to find any guidance on the matter. Anyone have thoughts or a good resource to point me to?

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