What are the tax consequences of an employee stock option being contributed to a TFSA? CRA responded:
[T]he property must be contributed to the TFSA at its fair market value (FMV) and the contribution is subject to the holder's unused TFSA contribution room. …The CRA is of the view that the intrinsic value of a warrant, option, or similar right is not reflective of the property's FMV.
Where a TFSA exercises an employee stock option, pursuant to paragraph 7(1)(c)… the employee is deemed to have received a benefit in the taxation year that the TFSA exercises the option equal to the amount by which the value of the shares acquired under the option exceeds the total of the amount paid by the TFSA to acquire the shares and the amount, if any, paid by the employee to acquire the option.
[P]roposed amendments were announced to prohibit asset transfer transactions (swaps) between TFSAs and other registered and non-registered accounts.