Amelie Desrocher, Chris D’Iorio, Alison Lantos, Fola Ogunamkin, Serena Hou, "Unlocking Value: Corporate Tax Deductions and Share-Based Compensation Strategies", Draft 2024 CTF Annual Conference paper

Summary Under
Tax Topics - Income Tax Act - Section 110 - Subsection 110(1) - Paragraph 110(1)(e)

Recharge agreement not required for s. 110(1)(e) deduction (p. 10)

  • The amount of the s. 110(1)(e) deduction is equal to the benefit deemed to...

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Summary Under
Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b)

Avoidance of s. 7(3)(b) through introducing employer discretion (pp. 12, 14)

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Summary Under
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b.1)

S. 7(1)(b.1) was response to Mathieu situation (p.16)

  • S. 7(1)(b.1) was added in 2010 to address situations like Mathieu, so as to ensure that...

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