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New technical interpretation issued by Canada Revenue Agency on stock options will spark debate

  • Fox Rothschild LLP
  • -
  • Canada, USA
  • -
  • November 8 2011

A recent technical interpretation issued by the Canada Revenue Agency, Technical Interpretation 2011-0393411E5, provides that under Article XV of the Canada-U.S. Income Tax Convention, that after 2008, when a U.S. resident employee of a Canadian resident corporation acquires shares of the corporation on the exercise of employee stock options, the Canada Revenue Agency (CRA) would disallow that the income from the taxable amount would qualify for exemption from Canadian income tax under the Canada-U.S. Tax Treaty, even if the employer was not present in Canada for more than 183 days

CRA confirms views on LTD payments to US resident

  • Thorsteinssons LLP
  • -
  • Canada, USA
  • -
  • November 3 2014

In 2014-0531441E5, the CRA confirmed that payments to a US resident under an unfunded long-term disability (LTD) plan by a Canadian employer would be

Employee stock plans 2012: year-end international reporting requirements

  • Jones Day
  • -
  • Australia, Canada, China, France, India, Ireland, Israel, Japan, Malaysia, Philippines, Singapore, Thailand, United Kingdom, USA, Vietnam
  • -
  • December 6 2012

This Commentary highlights some of the principal calendar and year-end reporting requirements for employee stock plans that U.S. companies most commonly encounter when offering these programs to their employees in selected jurisdictions worldwide

Canadian tax: recent changes to the employee stock options rules

  • Miller Thomson LLP
  • -
  • Canada
  • -
  • July 21 2010

Generally, pursuant to subsection 7(1) of the Income Tax Act (Canada) (the "Act") where an employer has agreed to sell securities of its capital stock to an employee, the employee is deemed to have received a taxable benefit from employment equal to the value of the securities at the time the employee acquired them, minus the total of the amount paid by the employee for the securities

No tax deduction for employee stock surrender payments

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • August 31 2012

The Supreme Court of Canada has dismissed an application for leave to appeal in Imperial Tobacco Canada Limited v The Queen

Tax-free savings account and employee stock options

  • McMillan LLP
  • -
  • Canada
  • -
  • October 14 2009

Taxpayers have generally avoided contributing public company employee stock options to a registered retirement savings plan (RRSP

Budget 2010 stock option changes may necessitate action by issuers

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • May 13 2010

As you may be aware, Budget 2010 contained a number of changes relevant to stock options

NFP Q&A: employer-provided parking can be a taxable benefit to an employee

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • February 5 2014

Although providing employees with parking may appear to be a benefit for employees, it can also adversely affect an employee (and even the employer

CRA administrative relief for retroactive lump sum payments in lieu of missed pension benefits

  • Borden Ladner Gervais LLP
  • -
  • Canada
  • -
  • May 22 2009

Delays in the commencement of pension benefit payments to a member or hisher survivor sometimes inadvertently occur

Federal Court of Appeal affirms tax court decision that payment to extinguish employee stock option plan is capital expenditure: Imperial Tobacco Canada Limited v. The Queen

  • Dentons
  • -
  • Canada
  • -
  • November 14 2011

On November 10, 2011, the Federal Court of Appeal (the “FCA”) delivered a unanimous decision in Imperial Tobacco Canada Limited v. The Queen, 2011 FCA 308