Chapter History S5-F4-C1, Income Tax Reporting Currency

Introduction

The purpose of a Chapter History page is to highlight any amendments to the information contained in an interpretation bulletin that is now reflected in a chapter of an income tax folio as well as to identify any subsequent amendments to a folio chapter. It outlines amendments that have been made as a result of legislative changes and proposed legislative changes, precedential court decisions, as well as new or revised interpretations of the CRA.

Except as otherwise noted, all statutory references herein are references to provisions of the Income Tax Act, R.S.C., 1985, c.1 (5th Supp.), as amended and all references to a Regulation are to the Income Tax Regulations, C.R.C., c. 945, as amended.

Update February 27, 2019

¶1.4, and 1.6 have been updated and 1.6.1 has been added to reflect amendments to the definition of the expression relevant spot rate in subsection 261(1). These changes were enacted on December 14, 2017 in S.C. 2017, c. 33, s. 81(1) [Bill C-63] and were effective March 1, 2017. This update also provides clarification regarding the use of an average rate of exchange.

¶1.5 has been updated to improve the clarity of the sentence.

¶1.8 and 1.19 have been updated to include reference to an exception found in subsection 20(14.2). Subsection 20(14.2) was introduced in the 2016 federal budget and enacted on December 15, 2016 (S.C. 2016, c. 12, s. 7(4)) applicable to transfers after 2016. Minor changes were also made for clarity.

¶1.20 and 1.22 have been updated to reflect the fact that the Bank of Canada no longer quotes a noon exchange rate.

¶1.23 has been updated to reflect the removal of the reference to “cumulative eligible capital in respect of a business” in subparagraph 261(7)(d)(i), enacted on December 15, 2016 (S.C. 2016, c. 12, s. 69(4)) and effective January 1, 2017.

¶1.32.1 and ¶1.50.1 have been added to reflect the introduction of subsections 261(10.1) and (14.1), enacted on December 15, 2016 (S.C. 2016, c. 12, s. 69(5) and (6)) and effective March 22, 2016.

Minor changes have also been made to the French version of the chapter to improve readability.

Update January 25, 2017

¶1.6 has been updated to take into account proposed amendments to the definition of the expression relevant spot rate in subsection 261(1). These changes were released by the Department of Finance on September 16, 2016 in Legislative Proposals Relating to the Income Tax Act and the Income Tax Regulations and to Related Legislation. 

¶1.15 has been updated to improve the clarity of the last sentence.