The CRA Provides its Opinion on the Application of the Benefit Rules in the Income Tax Act to the Issuance of Employee Stock Options

In 2013-0513771I7, the taxpayer asked whether paragraph 6(1)(a) and subsections 15(1), 56(2) and 56(4) would apply to a situation where employee stock options were issued by a public corporation to the shareholder of a private corporation that provides services to the public corporation. The CRA gave its view that subsections 56(2) and 56(4) would apply to the shareholder of the private corporation, subsection 15(1) would apply to the private corporation, and paragraph 6(1)(a) would apply to the employee.