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Henley v. The Queen, 2006 DTC 3431, 2006 TCC 347, aff'd supra 2008 DTC 6017, 2007 FCA 370

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Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) appreciation in warrants allocated to employees on capital account 186

Administrative Policy

7 February 2018 External T.I. 2016-0673331E5 - Stock Options - CCPCs

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Tax Topics - Income Tax Act - Section 9 - Computation of Profit stock options received by independent contractor valued at more than their intrinsic value 221

11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder 113
Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder 170
Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder 175
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 226
Tax Topics - Income Tax Act - Section 9 - Timing no s. 9(1) income inclusion from consultant being granted stock options until exercise 226
Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares 165

1 May 2013 Internal T.I. 2009-0321721I7 - Stock Option Recharge on Grant Date

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Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) stock option reimbursement in year of grant 298

1 December 2009 External T.I. 2009-0307821E5 - TFSA Contributions - Options and Warrants

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Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(c) contribution to TFSA – recognition deferred until exercise by TFSA 170

24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants

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Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (j) CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee 156
Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit 190
Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) application of farmout policy to situation where free warrants issued along with incurring of CEE 214

8 February 2005 Interpretation Case No. 52141

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Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) stock options valued based on in-the-money value 112
Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) subsequent exercise of stock option by independent contractor entailed exchange of financial services 103

15 July 2002 Internal T.I. 2002-0151247 - Stock Options Issued to Non-Employees

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3 May 2000 External T.I. 1999-0013915 - STOCK OPTIONS TO INDEPENDENT CONTRACTORS

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