Sell NSO received abroad, not yet vested in Japan

Hi all, a bit of a weird question that I could not specifically see answered on the sub.

I have a stock option grant from abroad that is large enough the taxation regime will affect my immediate liquidity. This grant is allocated several years back and vests in yearly increments. I am not a US citizen.

A few months back I moved to Japan. I am not paying resident tax yet, but I will do so from this year onward. If it matters, I will also have PR towards the end of the year assuming immigration processes at the usual speed.

Once the RSU reach a few years from grant, I can sell them tax free in the country where I’m from (Estonia).

* Assuming these stock options are now 3 years 6 months from the grant date, and they vest yearly
* Assuming I lived in Japan for, say, 4 months now (the stock vests yearly, so I haven’t vested in Japan)
* Assume the grant value is now 100,000 USD
* Assume the strike price is negligible, say 0.1 USD for the whole package, so the grant value is also the realized value.

Then I have vested (and can sell) 3/4 of the total amount, which is 75,000 USD
* None of this amount has been vested in Japan;
* however I spent 4/40 = 10% of the total time working here in Japan.

Assuming I now sell 75,000 USD of stocks, what is the amount for which I owe tax to the Japanese government?

1. 10% of the total vested amount, so tax on 7500 USD, or
2. nothing, since none of these NSO have vested in Japan, or
3. 10% of the total grant amound, so tax on 10,000 USD

Thank you in advance for any help.

by throwawAI_internbro

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