"Section 3701 of HR 3970, by Congressman Charles Rangel, is the ESOP S Corp provision ... Please note, the provision defines as an option any interest that is the same as what is defined as synthetic equity in IRC 409(p)(6)(C). The new tax provision would apply to options granted after the date of enactment. There is strong opposition to the entire bill, and enactment would be no earlier than some time in 2008, or perhaps even later, if ever."  MORE >>