See Also
Henley v. The Queen, 2006 DTC 3431, 2006 TCC 347, aff'd supra 2008 DTC 6017, 2007 FCA 370
Common share purchase warrants acquired by the taxpayer had a value at that time equal to their "in-the-money" value of 1 cent per warrant.
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|---|---|---|
| Tax Topics - Income Tax Act - Section 6 - Subsection 6(1) - Paragraph 6(1)(a) | appreciation in warrants allocated to employees on capital account | 190 |
Administrative Policy
S3-F10-C3 - Advantages – RRSPs, RESPs, RRIFs, RDSPs, FHSAs and TFSAs
Example 9 (warrants contributed at nominal intrinsic value)
Where an individual contributed common share warrants to his TFSA for their nominal...
7 February 2018 External T.I. 2016-0673331E5 - Stock Options - CCPCs
The s. 7 rules did not apply where an employee of a consulting company received, as part of his compensation, stock options that had been received...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | non-s. 7 stock options received by employee valued at more than their intrinsic value - and treated like securities on and after exercise | 222 |
11 March 2014 Internal T.I. 2013-0513221I7 F - Stock options
A consultant, but for such options being issued directly to its shareholder, would have been entitled to be granted stock options by a client...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | double income inclusion under s. 56(2) or (4) to consulting corporation, and under s. 15(1) to its shareholder, where consultant's options issued directly by client to shareholder | 113 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(2) | s. 56(2) benefit where corporation implicitly consented to consultant's options being issued by client directly to its shareholder | 170 |
| Tax Topics - Income Tax Act - Section 56 - Subsection 56(4) | implicit transfer by corporation when stock options earned by it were issued directly by its client to its shareholder | 175 |
| Tax Topics - Income Tax Act - Section 248 - Subsection 248(28) | s. 248(28) does not prevent a double income inclusion to corporation under s. 56 and shareholder under s. 15 | 226 |
| Tax Topics - Income Tax Act - Section 9 - Timing | no s. 9(1) income inclusion from consultant being granted stock options until exercise | 226 |
| Tax Topics - Income Tax Act - Section 52 - Subsection 52(1) | s. 15 benefit due to shareholder receipt of stock options earned by corporation added to the ACB of the exercised shares | 165 |
1 May 2013 Internal T.I. 2009-0321721I7 - Stock Option Recharge on Grant Date
Canco, a Canadian subsidiary of USCo, a publicly traded company, reimbursed USCo for the "fair value" of stock options granted by USCo to Canco's...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | stock option reimbursement in year of grant | 298 |
1 December 2009 External T.I. 2009-0307821E5 - TFSA Contributions - Options and Warrants
What are the tax consequences of an employee stock option being contributed to a TFSA? CRA responded:
[T]he property must be contributed to the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 7 - Subsection 7(1) - Paragraph 7(1)(c) | contribution to TFSA – recognition deferred until exercise by TFSA | 170 |
24 January 2011 Internal T.I. 2010-0389251I7 F - Farm-out agreement and warrants
A mining exploration corporation (the "Purchaser") agreed with another mining exploration corporation (the "Vendor") to acquire an interest in the...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (j) | CEE to be incurred under simple farmout reduced by an allocation to warrants issued by farmee | 156 |
| Tax Topics - Income Tax Act - Section 15 - Subsection 15(1) | valuation of “free” warrants issued as part of a simple farmout agreement determined based on what would be a s. 15(1) benefit | 190 |
| Tax Topics - Income Tax Act - Section 66.1 - Subsection 66.1(6) - Canadian exploration expense - Paragraph (f) | application of farmout policy to situation where free warrants issued along with incurring of CEE | 214 |
8 February 2005 Interpretation Case No. 52141
Respecting the issuance of stock options to an independent contractor as additional compensation for services rendered, CRA indicated that the...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 153 - Subsection 153(1) - Paragraph 153(1)(a) | stock options valued based on in-the-money value | 112 |
| Tax Topics - Excise Tax Act - Section 123 - Subsection 123(1) - Financial Service - Paragraph (d) | subsequent exercise of stock option by independent contractor entailed exchange of financial services | 103 |
15 July 2002 Internal T.I. 2002-0151247 - Stock Options Issued to Non-Employees
As there would be no market for an incentive option issued to a consultant by a Canadian corporation, and the exercise price at the time of grant...
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|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | no benefit at time of grant of incentive option to independent contractor | 55 |
3 May 2000 External T.I. 1999-0013915 - STOCK OPTIONS TO INDEPENDENT CONTRACTORS
The fair market value of an option "is the greater of:
- The trading value of the rights received; and
- The amount by which the fair market value of...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | 143 |