That seems correct: However, it is intended that statutory options are not considered nonqualified deferred compensation for purposes of the proposal. An exce

That seems correct: However, it is intended that statutory options are not considered nonqualified deferred compensation for purposes of the proposal. An exception is provided for that portion of a plan consisting of a transfer of property described in section 83 (other than stock options) or which consists of a trust to which section 402(b) applies. Page 209 of https://www.jct.gov/publications.html?func=download&id=5031&chk=5031&no_html=1 https://www.jct.gov/publications.html?func=download&id=5031&... But I'm not sure how this impacts ISOs with an 83(b) election.