Equity for Management

Equity for Management

by Paul B. Singer

Table of Content here

Table of CRA Documents here

EQUITY STRUCTURES NEWSLETTER

§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
§3009 Transaction Incentive
§3010 M&A Transactions
§3011 Offside Option Exchanges
§3012 Open Market Shares
§3013 How To Structure a 7(2) Trust
§3014 Making a “legally-binding” agreement

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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.

The treatise comprises more than 1,150 pages (575M words) of original commentary and is distributed both as a subscription service and a newsletter which together reach thousands of tax practitioners. The objectives of this comprehensive work are fourfold:

-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.