3 November 2023 APFF Financial Strategies and Instruments Roundtable Q. 6, 2023-0994241C6 F - Consequences of Transfer of DSUs to a corporation -- summary under Capital Property

In finding that the rights of an employee under a deferred share unit plan described in Reg. 6801(d) were not cap[ital property, and not eligible property that could be transferred to the employee’s personal holding company under s. 85(1), CRA stated that an “employee's rights under a DSU Plan generate income from an office or employment.”