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Imperial Tobacco redux an unwelcomed revisit to the deductibility of payments to option holders for surrendering stock options in the context of corporate reorganizations and acquisitions

  • Gowling Lafleur Henderson LLP
  • -
  • Canada
  • -
  • February 28 2011

Canada Revenue Agency ("CRA") generally permits the deduction of payments made by an employer to employees who surrender their options under an employee stock option plan ("ESOP") in the ordinary course of business