Options

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See Also

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

Common share purchase warrants acquired by the taxpayer had a value at that time equal to their "in-the-money" value of 1 cent per warrant.

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) appreciation in warrants allocated to employees on capital account 190

Administrative Policy

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

The s. 7 rules did not apply where an employee of a consulting company received, as part of his compensation, stock options that had been received...

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Tax Topics - Income Tax Act - Section 9 - Computation of Profit non-s. 7 stock options received by employee valued at more than their intrinsic value - and treated like securities on and after exercise 222

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

A consultant, but for such options being issued directly to its shareholder, would have been entitled to be granted stock options by a client...

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Locations of other summaries Wordcount
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

Canco, a Canadian subsidiary of USCo, a publicly traded company, reimbursed USCo for the "fair value" of stock options granted by USCo to Canco's...

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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

What are the tax consequences of an employee stock option being contributed to a TFSA? CRA responded:

[T]he property must be contributed to the...

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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

A mining exploration corporation (the "Purchaser") agreed with another mining exploration corporation (the "Vendor") to acquire an interest in the...

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Locations of other summaries Wordcount
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

Respecting the issuance of stock options to an independent contractor as additional compensation for services rendered, CRA indicated that the...

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Locations of other summaries Wordcount
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

As there would be no market for an incentive option issued to a consultant by a Canadian corporation, and the exercise price at the time of grant...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 9 - Computation of Profit no benefit at time of grant of incentive option to independent contractor 55

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

The fair market value of an option "is the greater of:

  • The trading value of the rights received; and
  • The amount by which the fair market value of...

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