CRA confirms that the exit tax exclusion for “rights” under a stock option “agreement” includes unvested rights under a free share plan

The exit tax in s. 128.1(4) does not apply to a "right" of an individual under "an agreement" referred to in s. 7(1).  CRA has confirmed that this exclusion includes unvested rights to receive shares (in this instance, "free" shares for which no exercise price will be paid) under "any arrangement under which a corporation agrees to issue its shares to one of its employees."

Neal Armstrong.  Summaries of 26 February 2014 T.I. 2013-0487961E5 under s. 128.1(10) – excluded right or interest and Treaties – Art. 15.