Regulation 6204

Subsection 6204(1)

Paragraph 6204(1)(a)

See Also

Birch Hill Equity Partners Management Inc. v Rogers Communications Inc., 2015 ONSC 7189

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Rectification & Rescission stock option deduction was peripheral to the larger share sale transaction 411

Administrative Policy

7 October 2011 Roundtable, 2011-0411951C6 F - Retenues à la source - options d'achat d'actions

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7 March 2007 External T.I. 2005-0157381E5 - Regulation 6204

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18 September 2001 External T.I. 2001-007148 -

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6 August 1992 T.I. (Tax Window, No. 23, p. 5, ¶2142)

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28 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 21, ¶1112)

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18 October 89 T.I. (March 1990 Access Letter, ¶1150)

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87 C.R. - Q.23

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Paragraph 6204(1)(b)

Cases

Montminy v. Canada, 2017 FCA 156

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(2) - Paragraph 6204(2)(c) acquisition right also ignored for purposes of Reg. 6204(1)(b) reasonable expectation test 238

See Also

Montminy v. The Queen, 2016 TCC 110, rev'd 2017 FCA 156

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Locations of other summaries Wordcount
Tax Topics - General Concepts - Fair Market Value - Shares capitalization of normalized cash flow accepted 381

Articles

Joint Committee, "Technical Amendments Package of September 16, 2016", Submission letter of 15 November 2016

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John McClure, Brian Kearl, "Stock Options in Spinout Transactions", Canadian Tax Highlights, Vol. 24, No. 7, July 2016, p. 7

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Subsection 6204(2)

Paragraph 6204(2)(c)

Cases

Montminy v. Canada, 2017 FCA 156

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Locations of other summaries Wordcount
Tax Topics - Income Tax Regulations - Regulation 6204 - Subsection 6204(1) - Paragraph 6204(1)(b) employees enjoyed the ½ deduction on exercising their stock options notwithstanding an immediate sale of the acquired shares to the controlling shareholder 479

Subsection 6204(3)

Administrative Policy

2006 Ruling 2005-0151001R3 - Prescribed Shares / plan of arrangement

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