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After noting that the stock option benefit would be exempt from Canadian tax under the exemption in para. 2 of Article XV of the Canada-US Convention, CRA asserted that this did not relieve USCo of its source deduction obligations: The corporation that has agreed to sell or issue the shares to the employee (in this case, Canco) will be considered to be the "payer" of the stock option benefit for purposes of paragraph 153(1)(a) (and will be responsible for the normal withholding), unless it receives reimbursement, in whole or in part, either directly or indirectly, in respect of the benefit. ...

2014 Ruling 2013-0516071R3- Reorganization-- summary under Paragraph 111(1)(a) Summary Under Tax Topics- Income Tax Act- Section 111- Subsection 111(1)- Paragraph 111(1)(a) transfer of already-earned profits to Lossco by transfer of LP units with income allocation at LP year end Background Profitco is wholly-owned by Foreign Parent 2 which, in turn, is indirectly wholly-owned by Foreign Parent 1. ...

Rulings include: the gain realized by Foreignco3 on the transfer of the Keep Shares to Canco in 2 and on the sale in 6 will be exempt from tax under Art. 13 of the Treaty. 55(2) will not apply to the deemed dividends arising in 4. ...

Rulings include: the gain realized by Foreignco3 on the transfer of the Keep Shares to Canco in 2 and on the sale in 6 will be exempt from tax under Art. 13 of the Treaty. 55(2) will not apply to the deemed dividends arising in 4. ...

In addition, paragraph 2 of Article 15 seems to contemplate that employers can be resident in a third country.... ...

Proposed transactions USco5 will finance a subscription by GP and Canco9 for units of FA1, by subscribing for preferred shares of Canco1 and 2, with those proceeds cascading down the stack of intervening partnerships and Canadian corporations through successive preferred unit and preferred share subscriptions. ...

In Scenario 2, Opco does not declare and pay the $100,000 dividend until after it has earns an additional $100,000 of income, and the FMV of Opco after the dividend is at least $1,000,000. ...

In Scenario 2, Opco does not declare and pay the $100,000 dividend until after it has earns an additional $100,000 of income, and the FMV of Opco after the dividend is at least $1,000,000. ...

Award No. 2 recognizing employees for having made additional efforts beyond the usual requirements of their position was taxable. ...

2) If so, is there any reason why it cannot be paid in the form of shares that were the subject of the s. 48.1 election? ...