Dov Begun, "Equity Based Compensation and Stock Options", 2017 Annual CTF Conference draft paper

Overview of SDA rules (p. 2)

If an arrangement constitutes an SDA, the following consequences result:

  • Subsection 6(11) deems an amount equal to...

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Need to avoid constructive receipt under a phantom plan (p. 4)

The CRA … interprets the word “received” in the ITA as referring to amounts...

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Need to avoid constructive receipt under a phantom plan (p. 4)

The CRA … interprets the word “received” in the ITA as referring to amounts...

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No withholding on s. 7(1.1) exercise (p.14)

[O]n the exercise of a CCPC option that complies with and is eligible for the deferral under...

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Retaining s. 110(1)(d) deduction following exercise price reduction (p. 15)

The paragraph 110(1)(d) deduction can also be preserved if, rather...

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Employee savings plan with company match (pp. 19-20)

[S]ome corporations will match the amounts contributed by their employees through payroll...

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