CRA Taxation on CCPC Stock option exercise for US resident

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CRA Taxation on CCPC Stock option exercise for US resident

Post by Raj123 » Fri Jan 18, 2019 6:42 pm

I read this article on your website. ... comparison

I have a question regarding CCPC stock option exercise while moving from Canada to US.

I got ISOs issued by CCPC in Canada on Nov 2014. (FMV = 90, Exercise Price = 100, vesting in Feb 2018)
I emigrated from Canada to US in July, 2016.
I exercised my ISO in April, 2018 (FMV = 1100, still holding shares and no plan to sell it)

Will I have to pay tax to the CRA?

The 5th protocol of US Canada treaty says that the stock exercise gains should be attributed based on the portion of time spend in Canada and US.

So in the US it will affect AMT.

However, I am not sure about the taxation by the CRA since these stock options are from a CCPC rather than a regular corporation. CRA doesn't tax Canadian resident on stock option exercise and they can defer those gains. Will that rule apply to me?

Thanks in advance!

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