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We have a transaction where a disqualified individual under 280G is getting stock options from the buyer.  These will be granted contingent on the change in control, but they will not begin to vest until a year after the closing, and then only monthly over several years.  

I understand that they are granted contingent on the change in control, but does the fact that they are unvested, and won't even begin to vest for a year, make a difference?

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