Tax Bulletin Special Edition Issue Number 7 Amendment to Paragraph 30

• at the time when the original option (or any replacement option) is assigned or released in exchange for a replacement option:

  (a) the total market value of the shares which would be acquired IF the replacement right were exercised at that time (regardless of whether exercise is actually possible at that time), less any consideration that would have to be given to acquire those shares,
  
  is substantially greater than

  (b) the total market value of the shares which would be acquired IF the right being assigned/released were exercised immediately before the release/ assignment of that right (regardless of whether exercise is actually possible at that time), less any consideration that would have to be given to acquire those shares.