Employees who receive security options include a taxable benefit in their employment income under certain circumstances. Also under certain circumstances employees can be entitled to deduct 50% of that employment inclusion as a deduction in computing taxable income.

Does this set of rules surrounding the 50% deduction for employee security options meet the "fairness" test for a tax system? In other words, is it fair that employees who receive security options and meet the criteria are entitled to receive the 50% deduction?

Discuss.