Subsection 7(2) - Securities held by trustee

Cases

MNR v. Chrysler Canada Ltd., 92 DTC 6346, [1992] 2 CTC 95 (FCTD)

After finding (below) that the Chrysler employee stock ownership plan was both an employee benefit plan and an agreement to issue shares to...

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Re MNR and Chrysler Canada Ltd., 91 DTC 5526, [1991] 2 CTC 156 (FCTD)

Chrysler (U.S.) contributed treasury shares to a trust for the benefit of its employees and those of Chrysler Canada. Chrysler Canada reimbursed...

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Administrative Policy

7 October 2021 APFF Roundtable Q. 1, 2021-0900891C6 F - Tax treatment of employee share trust

A discretionary trust for present and future employees of ABC Inc. that had held shares of ABC Inc. since January 1, 2021, will add Mr. X as a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Employee Benefit Plan the EBP rather than s. 7 rules applied to a share plan for employees where share distributions were discretionary 404

19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules

CRA first stated that Placer Dome, Chrysler and McAnulty “stand for the proposition that an arrangement to issue or sell shares need not be a...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) discretionary share bonus plans have no s. 7 agreement unless there is delayed vesting 371
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) no agreement to issue shares if vesting in employer's discretion 263

3 December 2009 External T.I. 2009-0311921E5 F - ESOP-US

Does s. 7 apply where a trust created under an employee stock ownership plan (the "Plan") acquires all of the shares of USCO and each year the...

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3 May 1994 External T.I. 9409755 - TAX ADJUSTMENT FOR FORFEITURE UNDER STOCK OPTION

S.7(2) deems an employee to have acquired a share at the time a trustee commences to hold it for the employee, even if the employee's entitlement...

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Articles

Ian MacDonald, "Trusts Holding Employee Shares - After the Initial Transfer", Taxation of Executive Compensation and Retirement, Vol 22, No.10, June 2011, p. 1415:

There are a number of indicators which suggest that an s. 7(2) trust is not governed by various employee benefit plan rules.