Equity for Management
Equity for Management
Tax-efficient planning for stock and stock-dependent interests
by Paul B. Singer
Volume I. INCENTIVES AND INVESTMENTS
The Agreement — The Offer — The Benefit — Benefits Outside Section 7 — Benefit Upon Conversion — Benefit From Trust — Benefit Upon Death — Bonus Or Restricted Shares — Benefit Deferral (CCPC) — Benefit Outside Employment — Benefit Deduction — Prescribed Shares — Election By Employer To Forego Deduction — Deferred Compensation — DSU — Share-Based Dividend Equivalents — RSU — Supplementary Pension — Other Deferrals — Non-Resident Benefit — US Treaty Benefit — Withholding And Reporting
Volume II. REORGANIZATION AND MONETIZATION
Family Option Transfers — Holdco Option Transfers — CCPC Share Dispositions — Paid-Up Capital — Selling Deferred Shares — Drawing Liquidity — Price Changes — Prescribed Share (PS) Acquisitions — PS Swaps — PS Agreements — Repricing Amendments — Gift Of Securities — Non-Qualified Securities (NQS) — NQS Awards — NQS Vesting Changes — Ordering NQS — NQS Deduction — Option Changes — Option Surrenders — Rights Ceasing To Be Exercisable — Option Exchanges — Deferred Share Exchanges — Settling DSUs — Unit Exchanges — Emigration And Immigration — Expensing — Option Expenditures — Share Expenditures — Capital Expenditures — Option Settlement Costs — Recharging
The service reports on how arrangements can be efficiently designed. Recent release:
§3001 EPSP For start-up
§3002 Marketmaking trust
§3003 RCA for Employee buyout
§3004 Monetizing option exits
§3005 Option transfer to holding corporation
§3006 Debentures for startups
§3007 Returning share capital
§3008 Tracking shares for carried interest
The service monitors existing arrangements for risk minimization. Recent release:
§4001 Open Market Share Sourcing
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Author
Paul B. Singer graduated from the law faculties of McGill and Oxford where he studied as a Rhodes Scholar. He worked in the Privy Council Office of Canada, taught tax law as a full-time professor and wrote a multi-volume treatise on corporate reorganization which he later edited for over 10 years, joined the tax group of one of the largest law firms in Canada where he practised tax law for fifteen years as an equity partner and vice-chair of the tax section and contributed many featured articles in specialized tax publications notably in the area of international branch tax planning and executive compensation, and then acted as founder or investor in ventures including publishing and software development. In 2022, he published a two-volume tax treatise titled “Equity for Management,” focusing on stock-dependent incentives. These plans, designed for Canadian employees, involve hundreds of thousands of participants and result in awards totaling billions of dollars.
-providing practical guidance to a wide range of tax professionals in law, accounting and business including major firms like Stikeman, Davies, EY, PwC, etc;
-pioneering the revision of plans and arrangements through initiatives like standardizing “change-in-control” provisions, with active participation from several major firms;
-formulating proposals for legislative tax reform and simplification, encompassing the codification of existing laws and administrative practices in this domain; and
-discussing challenges related to progressive personal taxation, including the potential erosion of the rule of law due to administrative discretion.
Table of Content here
Table of CRA Documents here