From Andrew Morreale, “Stock Option Deduction Is Available on Death” Canadian Tax Focus 5:3 (August 2015):
An employment benefit in respect of unexercised employee stock options that arises on death is eligible for the paragraph 110(1)(d) deduction through the use of a subsection 110(1.1) election, according to a new CRA technical interpretation (2013-0484181E5, May 4, 2015). The CRA states that eligibility will be allowed “on an administrative basis,” implying that the legal basis for eligibility is at least unclear and possibly non-existent.
