Canada: Change in Position on Allocation of Cross-Border Stock Option Benefits

The Canada Revenue Agency (CRA) has confirmed that it will apply the principles set out in the Commentary on Article 15 of the Organization for Economic Cooperation and Development Model Convention (OECD Commentary) when allocating a stock option benefit to Canada, unless an income tax treaty otherwise specifically applies. This change in CRA’s default approach applies to stock options exercised after 2012.

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By PwC

November 27, 2012