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AMT and ISOs involving IRS Form 6251 and Employer Provided 3921

I have read almost everything I could find on Turbotax's community on this topic and feel something is lacking in documentation or just my knowledge.

 

When filling out form 6251 regarding AMT tax calculation, line 2i (#3 below it in particular) brings in a figure for the bargain element of ISO exercises. This comes from an Exercise of Stock Options worksheet.

 

To my understanding based on everything I've read, this figure should be only for the stock options that were exercised and held at year end (December 31, 2025 in this case). Question 1: Is this correct?

 

Second, this appears to differ from the employer provided form 3921. Form 3921 lists all exercised options regardless of whether they were held or sold. I believe, in line with question 1, I should disregard those that were sold, and only report (on form 6251, line 2i, item #3) the ones that were still held at year end. Question 2: Does this sound correct that what I report here excludes some incentive stock options from 3921?

 

For those who might find this in the future, I filled out everything in Turbotax Desktop 2025's related to "ISO Exercise & Hold" under Federal Wages & Income. On this screen, there isn't any detail telling me what I should not enter. When I click forms and go to "6251 Wks," then click on line 2i's #3, it takes me to an "Exercise SO (employer Inc.)" form. On this page, I finally see an instruction to only include options that were held at year-end. Why is this so tucked away? Why is it not more obvious somewhere such as when I was filling out the "ISO Exercise & Hold" page to indicate which ones had been sold? This could have been a very costly error.

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Accepted Solutions
DavidD66
Expert Alumni

AMT and ISOs involving IRS Form 6251 and Employer Provided 3921

The answer to both Question 1 and Question 2 is: Yes, your understanding is correct.  The Incentive Stock Option (ISO) bargain element included in AMT Income would only be that bargain element for options exercised and still held at year end.  Any stock from the exercise of ISOs during the year that were also sold during the year would result in that bargain element being reported as ordinary income.  Since it is reported as income on Form W-2, there is no "Excess of AMT income over regular tax income" because the bargain element is included in both.  Since those options don't factor into the AMT calculation, they should not be included when entering form 3921.  

 

As for Question 3, I can't speak to why certain program instructions appear where they do and do not appear.  But I understand why you are asking.  

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2 Replies
DavidD66
Expert Alumni

AMT and ISOs involving IRS Form 6251 and Employer Provided 3921

The answer to both Question 1 and Question 2 is: Yes, your understanding is correct.  The Incentive Stock Option (ISO) bargain element included in AMT Income would only be that bargain element for options exercised and still held at year end.  Any stock from the exercise of ISOs during the year that were also sold during the year would result in that bargain element being reported as ordinary income.  Since it is reported as income on Form W-2, there is no "Excess of AMT income over regular tax income" because the bargain element is included in both.  Since those options don't factor into the AMT calculation, they should not be included when entering form 3921.  

 

As for Question 3, I can't speak to why certain program instructions appear where they do and do not appear.  But I understand why you are asking.  

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AMT and ISOs involving IRS Form 6251 and Employer Provided 3921

Thank you for replying DavidD66 - really appreciate it. I used a few various sources (including Claude and paid TurboTax Live support) on this to find alignment in the answer and your response is the most valuable/critical. 

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