[sokoloff]

Should taxpayers be forced to amend prior years' returns based on a new tax policy? (I believe no.)

If this policy were passed and applied to retroactively vested (but not yet received due to a time, performance, or other double trigger), that's what would seem to need to happen.

Other people have made plans for retirement or other meaningful milestones based on the current tax law. There is value in having stability and being able to plan around tax and other long-term financial realities.

Further, due to performance-dependent multipliers, it's often not even possible to know what the amount should be (which I admit applies to both grandfathered and not grandfathered comp).