[iandanforth]

Can you go into a bit more detail on what counts as liquidity? Can I sell on a secondary market? Can a bank let me guarantee a loan based on my current units? Can non-liquid units be transferred to my next of kin tax free?

[jedberg]

These are all details that would have to be worked out, but the gist of it would be that you shouldn't be taxed on it until you're able to sell it. But I'll give it a shot:

> Can I sell on a secondary market?

Sure, and then you get taxed on the money you made, where your basis is $0.

> Can a bank let me guarantee a loan based on my current units?

That's tricky because it would be a way for people to work around the law. What if we made you pay tax if you took out a loan with the stock as collateral?

> Can non-liquid units be transferred to my next of kin tax free?

Seems like it would be reasonable to allow that. The value would still be $0, but when it became liquid, your next of kin would have to pay taxes on the value with a basis of $0, which would make it not a good workaround for estate tax since you would save money if you transferred it under the $5M lifetime limit.