2004 Ruling 2004-0088601R3 - RSU plan wherein units can be converted to DSUs -- summary under Paragraph (k)

underline;">: RSU Plan. The Company will establish to "Bonus Plans:" an RSU Plan and a PRSU Plan. "Particular Awards" will be granted to RSU Participants as a bonus for services rendered in the year of award. RSUs allocated will be equal to dividing the Particular Award amount by the current share price. Within XX days of the Maturity Date (being generally the 3rd anniversary of the Particular Award) the RSU Participant will be entitled to receive a lump sum cash payment based on the current trading price of shares and the number of RSU Units. On termination of service before the Maturity Date for a Particular Award (other than retirement or death) or engaging in prohibited conduct, RSUs previously allocated will be reduced or forfeited. An RSU Participant who is an active employee and is so invited by the may irrevocably elect to convert RSUs into DSUs, provided that the election is made during a period ending XX days before the Maturity Date.

PRSU Plan

The PRSU Plan is similar except that awards of units are divided in thirds, with the number of units associated with each third adjusted at the 1st, 2nd, and 3rd anniversary of the award based on a "performance factor" (i.e., based on meeting specified targets for the year).

Rulings

. Include that neither Bonus Plan will be a salary deferral arrangement by virtue of Para. (k) of the definition. No amount will be included in a participant's income on the allocation of units under the Bonus Ploans, or on conversion of such units to DSUs (the summary noting that no amount is thereby received). The proposed amendments to the DSU Plan (to accommodate conversions) will not cause it to fall outside Reg.6801(d).

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