CRA confirms flexibility as to which corporation in a private group settles an s. 15(2.5) employee buy/sell trust

Parentco, a private corporation, wholly owns Opcos, each of which has employees who, under an employee ownership plan, are allowed to acquire and sell shares of Parentco. To this end, a trust intended to comply with the s. 15(2.5) exception from s. 15(2), will purchase and sell, for their FMV, Parentco shares to and from the employees.

CRA confirmed that, as permitted under s. 15(2.5), Parentco or any of the Opcos could settle the trust for the purpose of purchasing and selling the shares of Parentco from or to eligible employees of Parentco or of any or all of the Opcos.

Neal Armstrong. Summary of 10 October 2025 External T.I. 2025-1076451E5 under s. 15(2.5).