Subsection 110(0.1)
Vesting Year
Articles
Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(e) | effective date/different employer and issuer/successor rules | 136 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.31) | exclude non-qualified securities/exclusion of under-water securities or where options cancelled | 165 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.9) | same-day notice requirement - impracticable | 28 |
Subsection 110(1) - Deductions permitted
Paragraph 110(1)(d) - Employee options
See Also
McAnulty v. The Queen, 2001 DTC 942 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | stock option agreement effective time of oral agreement (not yet ratified by board) | 146 |
Bernier v. The Queen, 97 DTC 317 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Illegality | 119 |
Amirault v. MNR, 90 DTC 1330 (TCC)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Effective Date | retroactive amendment to option price accepted | 39 |
Administrative Policy
2005 Ruling 2005-0120771R3 - Stock option plan
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | full deductibility of cash surrender payment made on surrender of options granted on common shares tracking appreciation in partnership interest | 200 |
19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | discretionary share bonus plans have no s. 7 agreement unless there is delayed vesting | 323 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(2) | no agreement if allocation of shares in trustee's discretion | 242 |
3 August 2016 External T.I. 2015-0572381E5 - Employee Stock Option-CCPC Shares
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | s. 7(1)(a) inapplicable where shares issued equal to in-the-money value | 85 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d.1) | not available where share payment of in-the-money value | 65 |
21 December 2012 Internal T.I. 2009-0327221I7 - Paragraph 7(1)(e) - Death of a Taxpayer
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 164 - Subsection 164(6.1) | 215 | |
| Tax Topics - Income Tax Act - Section 164 - Subsection 164(6.4) | 91 | |
| Tax Topics - Income Tax Act - Section 54 - Capital Property | 99 | |
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | FMV basis for stock options received by estate | 99 |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(e) | 91 |
Income Tax Technical News No. 19, 16 June 2000
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | 38 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.3) | 10 |
2004 Ruling 2004-007382 -
8 March 2001 External T.I. 2001-007044 -
15 October 1997 T.I. 972531
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 47 - Subsection 47(1) | 6 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.3) | 65 |
28 April 1995 T.I. 9850344
May 1995 Executive Institute Revenue Canada Round Table, Q. 24 (C.T.O "Employee Stock Option")
11 June 1993 T.I. (Tax Window, No. 31, p. 10, ¶2519)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | 83 | |
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | 101 |
13 January 1993 External T.I. 5-923395 -
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Words and Phrases
reorganization| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.5) | 81 |
92 C.R. - Q.46
4 May 1992 Tax Executive's Round Table, Question 10 (December 1992 Access Letter, p. 48)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | 33 |
5 March 1991 T.I. (Tax Window, No. 2, p. 19, ¶1184)
8 September 89 Memorandum (February 1990 Access Letter, ¶1114)
Articles
Joint Committee, "Stock Option Changes Announced in 2019 Federal Budget", 14 May 2019 Submission of Joint Committee
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(3) - Paragraph 7(3)(b) | submission re confirmation of employer deductibility where full employee benefit | 253 |
Colin Smith, "Re-pricing Employee Stock Options", Taxation of Executive Compensation and Retirement, December/January 2002, p. 63.
Eva Krasa, "Participation by Canadian Employees in U.S. Stock Option Plans: Some Issues", Taxation of Executive Compensation and Retirement, Vol. 12, No. 9, May 2001, p. 429
Julie Y. Lee, "Attracting and Retaining Executives and Employees With Tax-Efficient Incentives", Canadian Petroleum Tax Journal, Vol. 14, No. 1, 2001
Michael F.T. Addison, Gil J. Korn, "Employee Stock Options: An Up-Date", Personal Tax Planning, 2000 Canadian Tax Journal, Vol, 48, No. 3, p. 778.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | 0 |
Subparagraph 110(1)(d)(ii)
Clause 110(1)(d)(ii)(A)
Articles
Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper
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Paragraph 110(1)(d.01)
Administrative Policy
7 October 2011 Roundtable, 2011-0407951C6 F - Options, don d'actions
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8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(2.1) | donation funded with proceeds of short hedge put on immediately on s. 7 exercise does not qualify | 128 |
8 October 2010 Roundtable, 2010-0370501C6 F - Options, don, coût moyen, PBR
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.31) | taxpayer who does not make the s. 7(1.31) identification is subject to s. 7(1.3) | 136 |
Paragraph 110(1)(d.1)
Administrative Policy
3 August 2016 External T.I. 2015-0572381E5 - Employee Stock Option-CCPC Shares
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(b) | s. 7(1)(a) inapplicable where shares issued equal to in-the-money value | 85 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) | no 110(1)(d) where share payment of in-the-money value | 110 |
Paragraph 110(1)(e)
Articles
Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(0.1) - Vesting Year | reference to reasonably foreseeable timing/pro rata vesting | 54 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.31) | exclude non-qualified securities/exclusion of under-water securities or where options cancelled | 165 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.9) | same-day notice requirement - impracticable | 28 |
Paragraph 110(1)(f) - Deductions for payments
See Also
Administrative Policy
Subparagraph 110(1)(f)(i)
Administrative Policy
16 May 2016 External T.I. 2015-0571591E5 - Employees Provident Fund of Malaysia
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(1) - Superannuation or Pension Benefit | pension plan characteristics | 160 |
| Tax Topics - Income Tax Act - Section 60 - Paragraph 60(j) | paraphrase | 55 |
30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(1) | EU withholding does not qualify as state tax | 116 |
| Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) | pension income not employment income | 70 |
30 January 2013 External T.I. 2012-0449621E5 F - Belgian pension
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Treaties - Income Tax Conventions - Article 18 | Belgian social security payment received by Canadan resident must be included in the personal return, but with offsetting s 110(1)(f)(i) deduction claimed | 142 |
Subparagraph 110(1)(f)(ii)
Administrative Policy
22 February 2012 External T.I. 2011-0421671E5 F - Loss of retirement income benefit - death
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(1) - Paragraph 56(1)(v) | inclusion under s. 56(1)(v), offsetting deduction under s. 110(1)(f)(ii), for Ontario WSIB lump sum on death | 46 |
Subparagraph 110(1)(f)(iii)
See Also
Lapierre v. The Queen, 2019 TCC 18
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Regulations - Regulation 8900 - Subsection 8900(1) - Paragraph 8900(1)(b) | UN-authorized agency was not a UN agency | 114 |
| Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(a) | agency was not a NATO subsidiary non-military body | 128 |
Paragraph 110(1)(j) - Home relocation loan
Administrative Policy
25 May 1994 T.I. 941081 (C.T.O. "Home Relocation Loans")
Subsection 110(1.1) - Election by particular qualifying person
Administrative Policy
21 November 2017 CTF Roundtable Q. 9, 2017-0724191C6 - Stock Option Deduction
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18 August 2017 External T.I. 2016-0672931E5 - Election
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7 December 2015 External T.I. 2015-0585171E5 F - 7(1)(b) benefit and 110(1.1) election
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4 May 2015 External T.I. 2013-0484181E5 - 7(1)(e) benefit and 110(1.1) election
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11 December 2012 External T.I. 2011-0423441E5 F - Options d'achat d'actions et décès
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 69 - Subsection 69(1) - Paragraph 69(1)(c) | cost to estate of employee stock options determined under s. 69(1)(c) | 90 |
Subsection 110(1.31)
Articles
Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(e) | effective date/different employer and issuer/successor rules | 136 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(0.1) - Vesting Year | reference to reasonably foreseeable timing/pro rata vesting | 54 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.9) | same-day notice requirement - impracticable | 28 |
Subsection 110(1.4) - Replacement of home relocation loan
Subsection 110(1.5) - Determination of amounts relating to employee security options
Administrative Policy
13 January 1993 External T.I. 5-923395 -
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d) | 59 |
Paragraph 110(1.5)(a)
See Also
Ferlaino v. The Queen, 2016 TCC 105 (Informal Procedure)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(a) | exercise price of employee stock options to be translated at the exercise-date spot rate | 201 |
| Tax Topics - Income Tax Act - Section 261 - Subsection 261(2) | exercise price of employee stock options to be translated at the exercise-date spot rate | 109 |
Subsection 110(1.8) - Conditions for subsection (1.7) to apply
Articles
Dov Begun, "Equity Based Compensation and Stock Options", 2017 Annual CTF Conference draft paper
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Steve Suarez, Firoz Ahmed, "Public Company Non-Butterfly Spinouts", 2003 Conference Report, c. 32.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 55 - Subsection 55(2) | 0 | |
| Tax Topics - Income Tax Act - Section 84 - Subsection 84(2) | 0 |
Subsection 110(1.9)
Articles
Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(e) | effective date/different employer and issuer/successor rules | 136 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(0.1) - Vesting Year | reference to reasonably foreseeable timing/pro rata vesting | 54 |
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.31) | exclude non-qualified securities/exclusion of under-water securities or where options cancelled | 165 |
Subsection 110(2) - Charitable gifts
Cases
Administrative Policy
11 July 1991 T.I. (Tax Window, No. 6, p. 13, ¶1348)
IT-86R "Vow of Perpetual Poverty".
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 118.1 - Subsection 118.1(1) - Total Charitable Gifts | 65 |
Articles
Strain, "Capital Gains Exemption: To Crystallize or not to Crystallize - Emerging Income Tax Issues", 1991 Conference Report, p. 8:7.
Subsection 110(2.1) - Charitable donation — proceeds of disposition of employee option securities
Administrative Policy
6 December 2016 External T.I. 2015-0605971E5 - Paragraph 110(1)(d.01) deduction
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1.31) | s. 7(1.31) election also effective where a broker sale under s. 110(2.1) | 146 |
8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1)
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| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1) - Paragraph 110(1)(d.01) | cashless exercise does not satisfy ss. 110(2.1) and 110(1)(d.01) | 42 |