"The final rules make no changes to the original IRS proposal. They clarify that the transition relief ... expires at different dates depending on the type of equity grant made: [1] Stock options, stock appreciation rights and restricted stock: For these types of grants, the transition relief applies to all grants made on or before the end of the transition period.... [2] Restricted stock units and phantom shares: For these types of grants, the transition relief applies only to compensation paid on or before the end of the transition period."