Section 49

Subsection 49(1) - Granting of options

See Also

CIR v. Scottish Provident Institution, [2004] UKHL 52

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Ownership commercially realistic prospect of put and call not being exercised 155

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187

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Words and Phrases
option exercise
Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(3) 141

Kopec v. Pyret, [1987] 3 WWR 449 (Sask. C.A.)

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Canadian Long Island Petroleums Ltd. et al. v. Irving Industries Ltd., [1974] 6 WWR 385, [1975] 2 S.C.R. 715

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Administrative Policy

18 July 2011 External T.I. 2010-0370561E5 F - Location avec option d'achat

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Substance lease is a lease in the absence of sham 86
Tax Topics - Income Tax Act - Section 68 where lease is coupled with bargain purchase option, a portion of the rents must be allocated to option proceeds 137

Income Tax Technical News No. 44 13 April 2011 [archived]

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2004 APFF Roundtable Q. 13, 2004-008699 -

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92 C.R. - Q.51

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IT-96R5 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(3) 0

Articles

Jack Bernstein, "Canadian Tax Treatment of Index Participation Units and Exchange Traded Index Derivates", 35 Tax Notes International, 20 September 2004, p. 1107.

Watkins, "Equity Exchangeable Debentures and Appreciation Rights", 1993 Conference Report, C. 20; and Kingissepp, "Summaries of Corporate Finance Panel Discussion", 1993 Conference Report, C. 21

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Subsection 49(2) - Expired option — shares

See Also

Garner v. Pounds Shipowners and Shipbreakers Ltd., [1997] BTC 223 (Ch. D.)

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Subsection 49(3) - Where option to acquire exercised

Cases

Salt v. The Queen, 84 DTC 6395, [1984] CTC 414 (FCTD)

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See Also

Mitsui & Co. (Canada) Ltd. v. Royal Bank of Canada, [1995] 2 S.C.R. 187

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Administrative Policy

28 November 2001 Internal T.I. 2001-009124

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2003 Ruling 2003-002803 -

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Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) 155

6 September 1994 Memorandum 941986 and 942090 (C.T.O. "Are Special Warrants Flow-through Shares?)

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IT-96R5 "Options Granted by Corporations to Acquire Shares, Bonds or Debentures"

Locations of other summaries Wordcount
Tax Topics - Income Tax Act - Section 49 - Subsection 49(1) 0

Subsection 49(5) - Idem [Reassessment where option exercised in subsequent year]