> the FMV and strike price are equivalent at time of grant (now) [therefore] there is not yet any inherent "value" to these options.

i think the implication here may not be correct: one component of the value of options comes from max(market price - strike price, 0), a second component comes from time value -- i.e. the expected value of the option before it expires. since there is some probability that in future the market price of the stock will exceed the strike price before the options expire, there is some strictly nonzero time value component.

i cannot comment on the tax situation. the time value component clearly has some positive value to a speculator.