The Directorate noted that upon exercise, s. 7(1.1) provides that the s. 7(1)(a) benefit was deemed to not be received by the employee until the subsequent taxation year of disposition of the shares. However, although s. 153(1.01) “generally ensures that an amount deemed to be received as a benefit under paragraph 7(1)(a) is subject to the withholding and remittance requirements in subsection 153(1) as if it were a bonus”:
paragraph 153(1.01)(b) excludes from these requirements any amount deemed to have been received in a taxation year as a benefit because of a disposition of securities to which subsection 7(1.1) applies. Accordingly, no withholding would be required under subsection 153(1) in the situation described above.