We have considered global tax situation and there is no notional value attached in any tax regime RD to assess tax on shares whose value is contingent upon successful Registration filing with SEC, the success of the IPO itself and then business combination. Neither in the US nor in Norway nor in India or Singapore ...
Our tax wing can consult on the same ;-) -- But I definitely advise individuals to have their tax attorney plan and opine on these matters...
But as a tax professional myself, to the best of my knowledge, we have thoroughly researched this subject even before i have penned subscription request... :-)