DiscoverAdvisory ExplainedUnpacking Section 8C and Restricted Shares
Unpacking Section 8C and Restricted Shares

Unpacking Section 8C and Restricted Shares

Update: 2025-11-27
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In this episode of Advisory Explained, host Kosie Kritzinger is joined once again by Bobby Wessels from AJM as they lift the lid on Section 8C of the Income Tax Act - the rule that turns equity-based remuneration into ordinary income once restrictions fall away.



The discussion unpacks what Section 8C is, how it works, and the role of employment-specific restrictions and vesting dates. They also explore the cashflow implications at vesting, the interaction between share-options and phantom-share schemes, and why these alternatives don’t avoid the 8C rules.



Listeners will also hear about the potential benefits of Section 8C, along with key takeaways and red flags to look out for when dealing with restricted shares or employee share-incentive schemes.



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Unpacking Section 8C and Restricted Shares

Unpacking Section 8C and Restricted Shares

Kosie Kritzinger