Income Tax Act — I-3.3 261
(c) if the later year is a reversionary year of the taxpayer and the current year is a Canadian currency year of the taxpayer, the following amounts (expressed in the taxpayer’s elected functional currency) are to be converted to Canadian currency using the relevant spot rate for the last day of the taxpayer’s last Canadian currency year: (i) the amount that would be determined under clause (b)(i)(A) in respect of the particular amount if the current year were a functional currency year of the taxpayer, and (ii) any amount so deducted in computing the taxpayer’s Canadian tax results for a functional currency year of the taxpayer; and (d) in any other case, this subsection does not apply. Windings-up (16) If a winding-up described in subsection 88(1) commences at any time (referred to in this subsection as the “commencement time”) and the parent and the subsidiary referred to in that subsection would, in the absence of this subsection, have different tax reporting currencies at the commencement time, the following rules apply for the purposes of determining the subsidiary’s Canadian tax results for its taxation years that end after the commencement time: (a) where the subsidiary’s tax reporting currency is Canadian currency, (i) notwithstanding subsection (3), subsection (5) is deemed to apply to the subsidiary in respect of its taxation year that includes the commencement time and each of its subsequent taxation years, if any, (ii) the subsidiary is deemed to have as its elected functional currency the parent’s tax reporting currency, and (iii) if the subsidiary’s taxation year that includes the commencement time would, in the absence of this subsection, be a reversionary year of the subsidiary, this section is to be read with any modifications that the circumstances require; and (b) where the subsidiary’s tax reporting currency is not Canadian currency, (i) the subsidiary is deemed to have filed, at the time that is six months and one day before the beginning of its taxation year that includes the commencement time, in prescribed form and manner, a notice of revocation described in subsection (4), and (ii) if the parent’s tax reporting currency is not Canadian currency, (A) the subsidiary’s first reversionary year is deemed to have ended at the particular time that is immediately after the time at which it began, (B) a new taxation year of the subsidiary is deemed to have begun immediately after the particular time, (C) notwithstanding subsection (3), subsection (5) is deemed to apply to the subsidiary in respect of its taxation year that includes the commencement time and each of its subsequent taxation years, if any, and (D) the subsidiary is deemed to have as its elected functional currency the parent’s tax reporting currency. Amalgamations (17) If a predecessor corporation and the new corporation, in respect of an amalgamation within the meaning of subsection 87(1), have different tax reporting currencies for their last and first taxation years, respectively, paragraphs (16)(a) and (b) apply, for the purposes of determining the predecessor corporation’s Canadian tax results for its last taxation year, as if the tax reporting currencies referred to in those paragraphs were the tax reporting currencies referred to in this subsection and as if the references in those paragraphs to (a) “subsidiary” were references to “predecessor corporation”; (b) “parent” were references to “new corporation”; and (c) “taxation year that includes the commencement time” were references to “last taxation year”. Amalgamation — deemed application of subsection (5) (17.1) Notwithstanding subsection (3), if each predecessor corporation in respect of an amalgamation (within the meaning assigned by subsection 87(1)) has the same elected functional currency for its last taxation year, then, unless a predecessor corporation has filed a notice of revocation under subsection (4) on or before the day that is six months before the end of its last taxation