The author argues that Canada has no right to tax the benefit resulting from the exercise or realization of employee stock options on shares of non-Canadian corporations with no connection to Canada if such options are exercised after the employee has departed Canada and has established residence in a treaty jurisdiction and the individual is present in Canada in the year of exercise or realization for less than 183 days.
The author argues that Canada has no right to tax the benefit resulting from the exercise or realization of employee stock options on shares of non-Canadian corporations with no connection to Canada if such options are exercised after the employee has departed Canada and has established residence in a treaty jurisdiction and the individual is present in Canada in the year of exercise or realization for less than 183 days.