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I am still confused, I think. I was under the impression that with ESP programs, it was just like buying stock with a basis of whatever you bought it for, usually some discount to the real value of the stock. I know the IRS is thinking about taxing that discount as income, but as far as I know, there are no holding requirements for such stock. If the stock is sold more than a year after purchase, it is a long-term gain; otherwise, it's a short-term gain.

What you're describing sounds like some sort of combination of an ESP program and stock options, but I may just be really confused.
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