Yup, although none of that 83(b) election stuff would apply to him. I have a lot of 83(b) stock in various companies, but it only works when you are given sock in a company. Generally the founders/owners, etc. *paid* for the stock in some way or another (hence owners), therefore they are entitled to the 15%, and I GUARANTEE he is 100% vested in his stock, he wouldn't have any vesting period so he would have full advantage of a divy payment.