Chucker
Capital gains-wise, I believe that whatever you paid for your 4 million shares of JPHC (for example let's say $1200.00 if you bought them at .0003) is your cost basis for (assuming you hold through the share exchange and receive .46232 x your shares= 1849280 sh of Paivis) your converted Paivis shares when you sell them in 1-2 years after the restrictions partly and totally lift. I don't believe they have formally set a record date yet for holders of JPHC so you could still sell your JPHC shares until they set the date and get whatever they would sell for (looks like they have locked-in a .0002 bid so you're probably better off holding and seeing what happens). Again, from what I have read, your cost basis for selling of those particular JPHC-for-Paivis exchanged shares in the future, will be whatever the amount you actually paid for your JPHC shares, not the current value of them in terms of APOA's PPS. At the example cost basis of $1200, all things remaining equal, Paivis would have to take a hell of an off the cliff nose dive for you to be out of the money--something like less than .0007. Could that happen, yeah, but is it likely?