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Latest Developments On January 31, 2025, the Canadian Minister of Finance and Intergovernmental Affairs announced a deferral of the entry into force of amendments to the capital gains inclusion rate increase (directly impacting stock option income inclusions). Originally set to take effect on June 25, 2024, the new effective date is now January 1, 2026. This announcement provides clarity on the administration of income tax withholdings on stock option income subject to the preferential regime…

After discussing the issues for a tax deduction for share-based awards in Israel in my last blog, I wanted to revisit another tax deduction conundrum, this time in Canada. In the past, the Canada Revenue Agency (CRA) generally has not allowed a local tax deduction for the cost of share-settled awards (other than under very narrow circumstances).  However, based on a technical interpretation released on April 12, 2017, the CRA updated its position such that…