specified stock compensation
(3) Specified stock compensation (A) In general The term “specified stock compensation” means payment (or right to payment) granted by the expatriated corporation (or by any member of the expanded affiliated group which includes such corporation) to any person in connection with the performance of services by a disqualified individual for such corporation or member if the value of such payment or right is based on (or determined by reference to) the value (or change in value) of stock in such corporation (or any such member). (B) Exceptions Such term shall not include— (i) any option to which part II of subchapter D of chapter 1 applies, or (ii) any payment or right to payment from a plan referred to in section 280G(b)(6).