Section 110

Table of Contents

Subsection 110(0.1)

Specified Person

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Non-consolidation where the qualifying person is a portfolio investment (pp. 7-8)

  • Since, under GAAP, “investment entities” are required to...

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Vesting Year

Articles

Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter

  • Para. (a) of the vesting year definition should refer to an event the timing of which is not reasonably foreseeable.
  • Para. (b) of the vesting...

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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)

The time at which the taxpayer's employer agreed to issue shares to her was the time at which the president called her to his desk and told her...

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Words and Phrases
agree agreement
Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date stock option agreement effective time of oral agreement (not yet ratified by board) 147

Bernier v. The Queen, 97 DTC 317, [1997] 1 CTC 2028 (TCC)

The taxpayer's employer issued employee stock options to the taxpayer and others. Later in the same year, the Quebec Securities Commission...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Illegality 125

Amirault v. MNR, 90 DTC 1330, [1990] 1 CTC 2432 (TCC)

The taxpayer originally was granted options to acquire shares of his employer at an exercise price equal to 90% of the market price of the shares...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date retroactive amendment to option price accepted 41

Administrative Policy

15 June 2022 STEP Roundtable Q. 17, 2022-0929511C6 - Deceased Taxpayer and Stock Options

Although 2009-0327221I7 and 2011-0423441E5 indicated that the 50% deduction under s. 110(1)(d) is not permitted to a deceased taxpayer, s....

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2005 Ruling 2005-0120771R3 - Stock option plan

The two equal partners (“PartnerCo1” and “PartnerCo2”) of “Partnership” subscribe for voting redeemable retractable preferred shares...

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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 204

19 September 2016 Internal T.I. 2016-0641841I7 - Employee stock option rules

CRA first stated that Placer Dome, Chrysler and McAnulty “stand for the proposition that an arrangement to issue or sell shares need not be a...

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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 371
Tax Topics - Income Tax Act - Section 7 - Subsection 7(2) no agreement if allocation of shares in trustee's discretion 284

3 August 2016 External T.I. 2015-0572381E5 - Employee Stock Option-CCPC Shares

A Canadian-controlled private corporation issues treasury shares to the employee holder of a stock option (with a fair market value exercise...

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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 91
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 67

21 December 2012 Internal T.I. 2009-0327221I7 - Paragraph 7(1)(e) - Death of a Taxpayer

In response to a question regarding an employer's reporting requirements where a deceased employee was deemed to have disposed of unexercised...

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Income Tax Technical News No. 19, 16 June 2000

"... Where an employee disposes of his or her rights under a securities option agreement in exchange for shares of the capital stock of the...

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2004 Ruling 2004-0073821R3 - Stock Option Plan Amendment - SAR

An employee stock option plan is amended by providing that each of the existing options will have an associated SAR added which entitles the...

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8 March 2001 External T.I. 2001-0070445 - Stock options exercised by a corporation

Where an employee has transferred employee stock options to a controlled corporation, the deduction under s. 110(1)(d) may not be available to the...

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15 October 1997 External T.I. 9725315 - CCPC OPTIONS

Although a reduction in the exercise price for an employee stock option would not give rise to a disposition of the option, such reduction would...

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28 April 1995 T.I. 9850344

(See also 21 October 1996 T.I. 5-963321.)

Where an annuitant transfers an employee stock option having an accrued gain to his RRSP with the RRSP...

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May 1995 Executive Institute Revenue Canada Round Table, Q. 24 (C.T.O "Employee Stock Option")

A deduction under s. 110(1)(d) may be deducted from a benefit included in income under s. 7(1)(e).

11 June 1993 T.I. (Tax Window, No. 31, p. 10, ¶2519)

Where an employee surrenders her rights under a phantom stock plan and receives an option to acquire shares in the employer company with an...

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13 January 1993 External T.I. 5-923395

RC does not as a general rule express an opinion on the reasonableness of a method proposed to be used in arriving at the fair market value of a...

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Words and Phrases
reorganization

92 C.R. - Q.46

Where a Canadian employee participates in a stock option plan where the relevant amounts are denominated in U.S. dollars, the requirements of s....

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4 May 1992 Tax Executive's Round Table, Question 10 (December 1992 Access Letter, p. 48)

Where the provisions of s. 110(1)(d) otherwise are met, an employee will be entitled to the deduction in respect of cash payments received by the...

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5 March 1991 T.I. (Tax Window, No. 2, p. 19, ¶1184)

For the purposes of determining the fair market value of the share, RC will not permit the deduction of a discount to reflect savings resulting...

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8 September 89 Memorandum (February 1990 Access Letter, ¶1114)

An option to acquire shares of a U.S. corporation with an exercise price expressed in U.S. dollars will cease to qualify if the Canadian dollar...

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87 C.R. - Q.22

The expression "at the time the agreement was made" in s. 110(1)(d)(iii) refers to the date on which an option to acquire a specific number of...

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Articles

Joint Committee, "Stock Option Changes Announced in 2019 Federal Budget", 14 May 2019 Submission of Joint Committee

The Joint Committee has provided comments on the 2019 Budget proposals to align Canada’s employee stock option rules with those in the U.S....

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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

Includes a list of features of U.S. plans that may be problematic for the deduction.

Julie Y. Lee, "Attracting and Retaining Executives and Employees With Tax-Efficient Incentives", Canadian Petroleum Tax Journal, Vol. 14, No. 1, 2001

Includes discussion of tandem share appreciation rights.

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.

Subparagraph 110(1)(d)(ii)

Administrative Policy

31 May 2004 Internal T.I. 2004-0077341I7 F - Déduction de 110(1)d) de la Loi

Before going on to find that the s. 110(1)(d) deduction was not available where the employee was entitled to a discount in purchasing shares of...

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares market price is a prima facie indication of share FMV 74

Clause 110(1)(d)(ii)(A)

Administrative Policy

29 May 2007 Internal T.I. 2006-0217401I7 F - 110(1)d): Moment de la conclusion de la convention

Employees of Opco (Participants”) were granted stock options by Opco pursuant to “Grant Agreements” which specified the number of Options...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 7 - Subsection 7(5) not giving exercise notice to employees who are not shareholders (so that they cannot exercise their options) may engage s. 7(5) 271

Articles

Peter Lee, Paul Stepak, "PE Investments in Canadian Companies", draft 2017 CTF Annual Conference paper

Difficulty of determining FMV of management’s optioned shares where they rank lower in the waterfall (pp.20-21)

[S]tock options are typically...

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Paragraph 110(1)(d.01)

Administrative Policy

7 October 2020 APFF Financial Strategies and Instruments Roundtable Q. 6, 2020-0851631C6 F - Options d’achat d’actions - disposition au décès

Can the s. 110(1)(d.01) deduction be made from a benefit deemed to have been received by a deceased employee under s. 7(1)(e) where, following the...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(e) s. 110(1)(d.01) gift deduction is unavailable against a s. 7(1)(e) stock option benefit 81

7 October 2011 Roundtable, 2011-0407951C6 F - Options, don d'actions

Where a private corporation issues stock options to its employees, which are "in the money" at the time of issuance, and it subsequently becomes a...

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8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1)

Where there is a gift of the proceeds from a short sale of optioned shares on the same day as the option is exercised in a cashless exercise, the...

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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 136

8 October 2010 Roundtable, 2010-0370501C6 F - Options, don, coût moyen, PBR

Options are exercised and the shares donated to a charity within 30 days. After noting that a taxpayer who does not make the s. 7(1.31)...

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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) 146

Paragraph 110(1)(d.1)

Administrative Policy

3 August 2016 External T.I. 2015-0572381E5 - Employee Stock Option-CCPC Shares

A Canadian-controlled private corporation issues treasury shares to the employee holder of a stock option (with a fair market value exercise...

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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 91
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 116

31 August 2000 External T.I. 2000-0032525 - Exchanged CCPC option, 110(1)(d.1)

Contrary to the earlier position in an 18 October 1999 TI (No. 991926), the Agency now is of the view "that paragraph 110(1)(d.1) of the Act could...

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Paragraph 110(1)(e)

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Issues respecting availability of the s. 110(1)(e) deduction (pp. 13-15)

  • In order for a s. 110(1)(e) deduction to be available to the employer...

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Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter

  • Both (i) the denial of the s. 110(1)(d) deduction for benefits respecting “non-qualified securities” and (ii) the granting of a corresponding...

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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

Whitney v. The Queen, 2001 DTC 423 (TCC)

Although the taxpayer's employer (the New Brunswick provincial government) was a self-insured employer for workers compensation purposes, the...

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Administrative Policy

3 March 2011 Internal T.I. 2010-0387281I7 F - Déduction - personnel des Forces canadiennes

In response to a query as to whether the taxpayer is considered a member of the Canadian Forces and if the missions in which the taxpayer has...

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Subparagraph 110(1)(f)(i)

Administrative Policy

16 May 2016 External T.I. 2015-0571591E5 - Employees Provident Fund of Malaysia

In connection with the possibility that the a lump sum payment received by a recent Canadian resident out of a Malaysian pension plan (namely, the...

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30 October 2014 External T.I. 2013-0500491E5 - Pension from XXXXXXXXXX

Tax is withheld by the European Union on a pension received by a Canadian resident from an EU organization and which is exempt from national tax...

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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 124
Tax Topics - Income Tax Act - Section 126 - Subsection 126(3) pension income not employment income 76

30 January 2013 External T.I. 2012-0449621E5 F - Belgian pension

Belgian social security payment received by Canadan resident , which were exempt under the Canada-Belgian Convnetion, were required to be included...

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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 148

Subparagraph 110(1)(f)(ii)

Administrative Policy

22 February 2012 External T.I. 2011-0421671E5 F - Loss of retirement income benefit - death

An injured worker was entitled to receive monthly payments from the Ontario Workplace Safety and Insurance Board ("WSIB") until 65, with a lump...

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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 48

11 October 1991 and 21 January 1992 T.I. (Tax Window, No. 11, p. 18, ¶1519)

A New Brunswick worker who (following the payment of worker's compensation benefits for 24 consecutive months) has an amount equal to 80% of the...

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Subparagraph 110(1)(f)(iii)

See Also

Lapierre v. The Queen, 2019 TCC 18

A Canadian resident, who was an employee of the International Security Assistance Force (ISAF) in Afghanistan serving as an international civilian...

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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 131
Tax Topics - Income Tax Act - Section 81 - Subsection 81(1) - Paragraph 81(1)(a) agency was not a NATO subsidiary non-military body 152

Administrative Policy

3 March 2005 External T.I. 2004-0096371E5 F - Revenu tiré d'un emploi et 110(1)f)(iii)

CRA indicated that the determination of whether the income was from employment or self-employment (a business) was to be made in accordance with...

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Paragraph 110(1)(j) - Home relocation loan

Administrative Policy

25 May 1994 Internal T.I. 9410817 - HOME RELOCATION LOANS

Where an employee in receipt of a home relocation loan is transferred again and pays off the first loan, and receives another loan which will...

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27 July 1989 T.I. (Dec. 89 Access Letter, ¶1049)

An employee is entitled to a deduction for a reimbursement by the employer of interest cost on a loan or mortgage taken out from a related party...

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Subsection 110(1.1) - Election by particular qualifying person

Administrative Policy

21 November 2017 CTF Roundtable Q. 9, 2017-0724191C6 - Stock Option Deduction

Where the employer files a valid election under s. 110(1.1), is the stock option deduction still available where the employee was issued treasury...

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18 August 2017 External T.I. 2016-0672931E5 - Election

A stock option plan also includes a cashless exercise provision that permits an employee to elect, in lieu of paying the exercise price and...

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7 December 2015 External T.I. 2015-0585171E5 F - 7(1)(b) benefit and 110(1.1) election

On the acquisition of all the shares of a CCPC (the “Corporation”) by an arm’s length third party, it also acquired all of the stock options...

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4 May 2015 External T.I. 2013-0484181E5 - 7(1)(e) benefit and 110(1.1) election

Can an employer make the s. 110(1.1) election where s. 7(1)(e) deems a deceased employee to have received an employment benefit in the year of...

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11 December 2012 External T.I. 2011-0423441E5 F - Options d'achat d'actions et décès

In response to a question on the consequences when a deceased individual owned options to acquire the shares of a public company, CRA stated...

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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) 96

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Ability to forego a corporate tax deduction on less than all the rights (pp. 12-13)

  • S. 110(1.1) has been amended to replace the reference to...

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Subsection 110(1.3)

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Potential to free-up annual limit room through exchange of underwater options (pp. 15-16)

  • If, for example, in 2022, an option agreement, that had...

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Subsection 110(1.31)

Administrative Policy

17 May 2022 IFA Roundtable Q. 11, 2022-0926411C6

The new non-qualified securities rules regarding specified persons (generally, large non-CCPCs) make the employee deduction under s. 110(1)(d)...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.4) requirement to issue s. 110(1.9) notice to employees re RSUs could be avoided by designating them as non-qualified securities under s. 110(1.4) 357

Articles

Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter

  • It is inappropriate for D(ii) of the formula to include the FMV of securities to be issued under earlier options where they were non-qualified...

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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

Administrative Policy

17 May 2022 IFA Roundtable Q. 11, 2022-0926411C6

S. 110(1.9) requires the employer to notify CRA where it has agreed to issue a non-qualified security, s. 110(1)(e)(vi) provides that...

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - 101-110 - Section 110 - Subsection 110(1.31) the non-qualified securities rules are being reviewed by Finance respecting options such as RSUs that can never generate a s. 110(1)(d) deduction 285

27 July 1989 T.I. (Dec. 89 A.L.)

S.110(1.4) permits a taxpayer to replace a home relocation loan with a new loan, but prohibits him from extending the five-year period in which...

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Subsection 110(1.42)

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Limited scope of ordering mechanism (p. 10)

  • The only ordering that occurs under s. 110(1.31) is ensuring that all other grants contemporaneous...

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Subsection 110(1.44)

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

No s. 110(1.1) election necessary where s. 110(1.44) applies

  • Since s. 110(1.44) is intended to have the same effect (of making a deduction...

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Subsection 110(1.5) - Determination of amounts relating to employee security options

Administrative Policy

13 January 1993 External T.I. 5-923395

"it is our view that where a corporation's existing capital structure provides for it, the issuance of additional shares by the corporation would...

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Paragraph 110(1.5)(a)

See Also

Ferlaino v. The Queen, 2016 TCC 105 (Informal Procedure)

Smith J rejected arguments of the taxpayer that the computation of his s. 7(1)(a) benefits on exercising options on the shares of the listed U.S....

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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 215
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 115

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

Retaining s. 110(1)(d) deduction following exercise price reduction (p. 15)

The paragraph 110(1)(d) deduction can also be preserved if, rather...

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Steve Suarez, Firoz Ahmed, "Public Company Non-Butterfly Spinouts", 2003 Conference Report, c. 32.

Subsection 110(1.9)

Articles

Paul Carenza, Chris D’Iorio, "Update on Equity-Based Compensation in Canada: Market Trends and Technical Developments", draft 2021 Conference Report paper (Canadian Tax Foundation)

Notice where employer is not the plan administrator (p. 13)

  • No specific form of notice is prescribed.
  • In the common situation where the Canadian...

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Joint Committee, "Employee Stock Option Amendments", 3 September 2019 Joint Committee Letter

  • Requiring same-day written notification (in para. (a)) can be impracticable – at least 30 days should be allowed.
  • Re para. (b), non-residents...

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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

Aubry v. The Queen, 76 DTC 6343, [1976] CTC 598 (FCTD)

A member of the Society of Jesus who had taken the vow of poverty was not entitled to the deduction because he paid some of his expenses directly...

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Administrative Policy

11 July 1991 T.I. (Tax Window, No. 6, p. 13, ¶1348)

RC will allow a taxable benefit under s. 6(1)(a) to be deducted under s. 110(2).

IT-86R "Vow of Perpetual Poverty".

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

Would a taxpayer be entitled to the s. 110(1)(d.01) deduction by virtue of s. 110(2.1) if he directed the approved broker to dispose of his shares...

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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) 155

8 October 2010 Roundtable, 2010-0370481C6 F - Don, vente d'actions acquises en vertu 7(1)

An investor short sells the same number of shares as those exercised on the same day as the exercise of the s. 7 options, and donates the proceeds...

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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) 44

Articles

Maureen Y. Berry, "Properly Structured Charitable Donations May Mitigate Source Deduction Woes", Taxation of Executive Compensation and Retirement, 2011, p. 1367

There is a source deduction advantage to a broker-directed donation of the proceeds received upon the disposition of optioned securities as...

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