Ann: Proposed issue of securities - 4DS, page-78

Yeah good call - "Gifting" is the wrong word, they're effectively performance options (safe to assume the agreement stipulates some conditions to be met for them to be able to exercise the options).

As your table suggests the only time there could be some tax considerations is if shares are issued as payment for services - which is not the case here, they are options. In the case of shares for services it is clearly a form of income.

In this case LC will have to pay to turn the options into shares once the conditions are met. There is no tax/income consideration until they sell them for a gain or loss. But there is nothing to declare re: unlisted options they're worth nothing until they're exercised.