The IRS won't let you. You're essentially suggesting discounting stock options: https://www.jdsupra.com/legalnews/section-409a-implications-of-discounted-37112

The IRS won't let you. You're essentially suggesting discounting stock options: https://www.jdsupra.com/legalnews/section-409a-implications-of-discounted-37112/ https://www.jdsupra.com/legalnews/section-409a-implications-...