Ferlaino – Tax Court of Canada requires the exercise price of employee stock options to be translated at the exercise-date spot rate

The former Director of Taxes at a large Canadian corporation argued unsuccessfully before Smith J that the computation of his s. 7(1)(a) benefits on exercising options on the shares of the listed U.S. parent should depart from the norm by translating his exercise price using the much higher exchange rate at the time of option grant, rather than the rate (of around par) at the time of exercise.

Neal Armstrong. Summaries of Ferlaino v. The Queen, 2016 TCC 105 under s. 7(1)(a) and s. 110(1.5)(a).