23 May 2000 Internal T.I. 2000-0015647 F - DONATIONS D'ACTIONS A UN EMPLOYE-CLE -- summary under Paragraph 6(1)(a)

An individual who held all the shares of an operating corporation (a small business corporation) and who wished to retire, gave 10% of his shares to a key employee. The Agency indicated that the value of the shares likely would be includable in the income of the employee pursuant to s. 6(1)(a) unless, unusually, the transfer to the key employee was made to the individual in his personal capacity rather than qua employee. If this were the case, then ss. 69(1)(b)(ii) and (c) would apply.