I am not a tax accountant so forgive me if this is off base. It is my understanding that, when you sell any of that company stock, you pay capital gains on the profit over the cost. The profit that is equal to that amount that you had when you did the NUA (in your case in 2007) is subject to LTCG but exempt from NII and the profit above that is ALSO subject to capital gains (possibly STCG if there is reinvested dividends less than a year old, otherwise LTCG) and IS subject to NII. In other words, if you sell at a higher price than what it was priced at when you moved the shares to a taxable account, I think you must pay some NII on it (assuming your MAGI triggers NII, of course). I do not believe you can avoid NII completely if the price has appreciated since when the NUA occurred. The way I read what you are saying leads me to think that you think you can avoid the NII perhaps until some year when your MAGI would drop enough so as to moot the NII. I hope I am wrong.
