2004 Ruling 2004-0056921R3 - stock options; conversion of plans -- summary under Paragraph 7(3)(a)

Ruling that s. 7(3)(a) would govern a plan under which a Canadian-controlled private corporation agrees to issue common shares and preferred shares to executives in replacement of a SAR plan and the executives have the right to sell the shares in specified circumstances to the corporate employer or (where it is advantageous to the executive from a tax perspective) to a nominee of the corporate employer.