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Stock Option Early Exercise And 83(b) Elections

I’ve had a lot of questions about early exercise as a manager and a leader. I personally think they are an important part of early stage startups option plans. Stock options are messy and Early Exercise is kind of a hack to work around some issues, but it’s one of the important band-aids in our comp toolbox.

Disclaimers

I am not a tax lawyer, a CPA, or a financial advisor. Nothing in this post is tax advice, legal advice, or a recommendation to take any specific action. The numbers here are simplified illustrations, not predictions of your tax bill. Talk to your accountant or your tax lawyer before you do anything with real money. Everyone’s financial situation is different, and the tax code has more edge cases than a dodecahedron.

Your employer should have resources—HR, legal, finance—that can help you navigate your specific situation. Ask them. That’s what they’re there for.

Your stock option plan may not have early exercise. Early exercise is more common in very young, early or small startups. If your startup is past series B, early exercise tends to have increasingly tough tradeoffs.

Why You Should Early Exercise

You can save a ton of money on taxes.

Stock options are funny in that you are taxed twice - when you buy them - when you sell them

When you sell them, it’s just like selling any stock you buy on the public markets. Either long term or short term capital gains. You can’t do anything about the sell-side taxes.

With respect to the buy-side taxes, early exercise can potentially eliminate them.

Say you have 10,000 stock options with a strike price of $1.

If you don’t early exercise, the company goes public and you buy and sell those options on the same day for about $100 each, the math works like this:

We’ll make a factually incorrect, but directionally correct assumption that your tax rate is about 35%. We’re using 35% and 20% throughout to keep the math clean. Your actual rates depend on your income, state, and filing status—and the long-term rate creeps toward 24% at higher incomes. The exact numbers change; the principle doesn’t.

  • You buy the options for $10,000
    • You pay taxes on the delta between what you pay and what they are worth
    • Your tax bill approx $990,000 * 35% = $346,500
  • You sell them for $1,000,000
    • You pay short term capital gains (short term because you bought and sold the same day — you never held the shares)
    • Your tax bill is an additional $346,500
  • You net out $297,000
    • $1,000,000 - $10,000 - $346,500 - $346,500
Amount Tax Rate Tax Bill
Buy 10,000 options $10,000
Buy-side tax on $990,000 gain 35% -$346,500
Sell shares $1,000,000
Short-term capital gains 35% -$346,500
Net $297,000

Here’s the rough math with early exercise. We are making the assumption that your long term capital gains taxes are around 20%.

  • You buy the options for $10,000, immediately after they are granted to you.
    • You pay taxes on the delta between what you pay and what they are worth
    • Since your strike price on the day they are granted is usually the fair market value, the delta is zero.
    • Your tax bill approx $0 * 35% = $0
  • time passes
  • and passes
  • and the company IPOs
  • and eventually the shares are worth $100 each
  • You sell them for $1,000,000
    • you pay long term capital gains
    • your tax bill is an additional $198,000
  • You net out $792,000
    • $1,000,000 - $10,000 - $0 - $198,000
Amount Tax Rate Tax Bill
Buy 10,000 options at grant $10,000
Buy-side tax ($0 gain) 35% $0
time passes…
Sell shares $1,000,000
Long-term capital gains 20% -$198,000
Net $792,000

You don’t have to early exercise the full amount of your grant. It’s ok to only exercise half, or only exercise what you can responsibly afford.

Why You Shouldn’t Early Exercise

You could lose everything. If the stock ends up being worthless, which is the result for the vast majority of startups, you’ve essentially lost that money you spent on early exercise.

  • You buy the options for $10,000, immediately after they are granted to you.
    • you pay taxes on the delta between what you pay and what they are worth
    • Since your strike price on the day they are granted is usually the fair market value, the delta is zero.
    • your tax bill approx $0 * 35% = $0
  • time passes
  • And the company misses payroll, the building is struck by a meteor over the weekend and the data center loses all production code and records. The company folds like cheap origami.
  • You are out $10,000
Amount Tax Rate Tax Bill
Buy 10,000 options at grant $10,000
Buy-side tax ($0 gain) 35% $0
meteor strikes…
Net -$10,000

If you don’t have the money, you shouldn’t early exercise. Don’t borrow money from friends or family to do this. There are legal horror stories of those friends and family claiming full or partial ownership of the stock you purchase.

Personally, I wouldn’t and don’t recommend that you rack up debt or a large credit card bill to do this. If you have a rainy day fund or a special opportunity fund, Early Exercise may be a reasonable use of that money.

How to Early Exercise & the Importance of 83(b) Election

DO NOT FORGET TO SEND IN YOUR 83(B) ELECTION

You have exactly 30 days from the date of exercise to file your 83(b) with the IRS. Miss this deadline and it’s gone forever. There are no extensions, no exceptions, no do-overs. Send it via certified mail or another service that provides a receipt — you need proof that you mailed it within the 30-day window. Years from now, when it matters, that receipt is your evidence.

Some services like Carta may offer to handle the 83(b) filing for you. That’s great if it works. But this is ultimately your responsibility and yours alone. Never assume that a third party — your employer, your lawyer, your equity management platform — has actually filed it on your behalf. Verify. Get confirmation. Keep the receipt. If it didn’t get filed, the IRS doesn’t care whose fault it was.

Here are the basic steps:

  1. Decide how many shares you’d like to early exercise. This can be any amount of your total grant. Call this number N
  2. Check your option grant to get your strike price. Call this number SP.
  3. Math: your total cost to exercise is N*SP
  4. You now have to pay that amount to the company.
    1. If your company uses a service like Carta, just login Carta, hook up your bank account and transfer over the money.
    2. If your company is doing it the old way, you have to talk to HR or Finance to see how you can early exercise and who to write the check to. You probably have to sign some documents as well, such as stock option exercise notice.
  5. Fill out the 83(b) election form
  6. You definitely need at least two copies. your employer may request a third copy.
    • on one of the copies, write: “Copy to be returned” in the top margin
  7. Make a simple cover letter. There is a template at the bottom of this blog post
  8. Make a self addressed stamped envelope
  9. Figure out where to send the 83(b). The IRS reorganizes their site regularly, so this link may or may not work: http://www.irs.gov/uac/Where-To-File-Addresses-for-Tax-Professionals — if it doesn’t, search irs.gov for “where to file 83b election” or “section 83b mailing address.” The info is there somewhere.
  10. In an envelope addressed to the address from step 9. above include
    • cover letter
    • one filled out copy of the 83(b) election
    • one filled out copy of the 83(b) election with “Copy to be returned” written on the top margin
    • the self-addressed stamped envelope
  11. Walk over to the post office and send via certified mail, return receipt requested
  12. Do a little dance. Take a shot of tequila. You deserve it.

I know I said it above, but it’s worth repeating: keep your certified mail receipt somewhere safe. It’s your proof to the IRS, years from now, that you filed on time. Lose it and you’re arguing with the government about a piece of paper you sent a decade ago. Don’t be that person.

The Three Outcomes, Side by Side

Scenario Cost Total Taxes Net
Early exercise, company folds $10,000 $0 -$10,000
No early exercise, same-day sale (35% + 35% STCG) $10,000 $693,000 $297,000
Early exercise, sell after IPO (0% + 20% LTCG) $10,000 $198,000 $792,000

Early exercise is a speculative investment. Most startups don’t work out and typically, you’ll be making this decision during the most optimistic chapter of a startup’s life, surrounded by people who believe.

You have to treat this as a risk. A $10,000 bet. Ten Grand Gamble. If the company hits, you keep an extra $495,000. If it doesn’t, you’re out $10,000. That’s the entire calculus.


Appendix: 83(b) Cover Letter Template

Date____________

VIA CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Department of the Treasury
Internal Revenue Service
ADDRESS FROM STEP 9 ABOVE

Dear Sir or Madam,

Enclosed for filing is an executed original and one copy of
an Election under Section 83(b) of the Internal Revenue 
Code of 1986, as amended, for me:

    Name:       ______________
    SSN:        ______________
    Address:    ______________
                ______________

Please acknowledge receipt of this document by date-stamping 
the copy and returning it to me in the self-addressed, 
stamped envelope provided.

Thank You,

YOUR NAME


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