Supreme Court grants leave in Des Groseillers

The Supreme Court has granted leave to appeal in Des Groseillers, in which the Quebec Court of Appeal had found (to refer to the ITA equivalents) that s. 69(1)(b) deemed there to be FMV proceeds for s. 7 purposes respecting an employee’s gift of stock options to arm’s-length registered charities, rather than the s. 7 rules constituting (having regard to s. 7(3)(a)) “a code so complete and airtight that the application of section [69] is excluded.”

Neal Armstrong. Summary of Agence du revenu du Québec v. Des Groseillers, 2021 QCCA 906, leave granted 24 March 2022, under s. 7(3)(a).