Warrants and SPTCs add zest to new share issues

"This month, Tax Notes focuses on two features which can potentially ""dress up"" a new issue of common shares to make the shares more attractive to investors. Attaching warrants to a share issue is a relatively common practice, and recent years have seen an imaginative variety of different kinds of warrants, some of which can be subject to somewhat different tax treatment . A less common financing strategy which certainly deserves some consideration involves the possibility of utilizing ""Share Purchase Tax Credits "" in conjunction with a new share issue.IntroductionPrevious subjects covered in Tax Notes have dealt with flow-through shares and other tax angles which can make equity issues more appealing to potential investor s. Two other techniques which can add zest to a new stock issue involve the utilization of warrants and ""share purchase tax credits"" (or SPTCs). This article takes a brief look at the better known subject of warrants and the lesser known matter of SPTCs.Of course, this paper presents only a relatively general summary of the income tax implications of warrants and SPTCs, and is not intended to be a definitive commentary on all of the detailed and complex tax issues that might be relevant in the circumstances."