Section 110

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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Words and Phrases
agree agreement
Locations of other summaries Wordcount
Tax Topics - General Concepts - Effective Date 146

Bernier v. The Queen, 97 DTC 317 (TCC)

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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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Income Tax Technical News No. 19, 16 June 2000

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2004 Ruling 2004-007382 -

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8 March 2001 External T.I. 2001-007044 -

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15 October 1997 T.I. 972531

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28 April 1995 T.I. 9850344

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

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

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13 January 1993 External T.I. 5-923395 -

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Words and Phrases
reorganization

92 C.R. - Q.46

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

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

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

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87 C.R. - Q.22

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Articles

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

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

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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)

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.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

30 August 2000 External T.I. 2000-003252 -

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Paragraph 110(1)(f) - Deductions for payments

See Also

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

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Subparagraph 110(1)(f)(i)

Administrative Policy

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

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

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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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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

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

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

Administrative Policy

25 May 1994 T.I. 941081 (C.T.O. "Home Relocation Loans")

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

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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

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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(1.4) - Replacement of home relocation loan

Administrative Policy

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

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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 -

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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.

Subsection 110(2) - Charitable gifts

Cases

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

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Administrative Policy

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

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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

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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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Articles

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

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