[devdas]

No, even better would be to trigger a revaluation of all stock values on that date, and tax the income (as normal income, not capital gains) as if 100% of their stock was sold at that price.

So if you hold 100 million shares valued at 1 USD/share, and sell 1 million at 2 USD/share, your tax liability will be assumed on you selling 100 million shares at 2 USD/share (or 200 million of regular income).

[SpelingBeeChamp]

Next time you use an illustrative example, I suggest using the simplest figures you can.

With respect to your example, it's exactly the same point and IMO easier to follow if you remove all instances of the word "million."