Income Tax Act — I-3.3 261
Definitions 261 (1) The following definitions apply in this section. Canadian currency year of a taxpayer means a taxation year that precedes the first functional currency year of the taxpayer. ( année de déclaration en monnaie canadienne ) Canadian tax results of a taxpayer for a taxation year means (a) the amount of the income, taxable income or taxable income earned in Canada of the taxpayer for the taxation year; (b) the amount (other than an amount payable on behalf of another person under subsection 153(1) or section 215) of tax or other amount payable under this Act by the taxpayer in respect of the taxation year; (c) the amount (other than an amount refundable on behalf of another person in respect of amounts payable on behalf of that person under subsection 153(1) or section 215) of tax or other amount refundable under this Act to the taxpayer in respect of the taxation year; and (d) any amount that is relevant in determining the amounts described in respect of the taxpayer under paragraphs (a) to (c). ( résultats fiscaux canadiens ) elected functional currency of a taxpayer means the currency of a country other than Canada that was the functional currency of the taxpayer for its first taxation year in respect of which it made an election under paragraph (3)(b). ( monnaie fonctionnelle choisie ) functional currency of a taxpayer for a taxation year means the currency of a country other than Canada if that currency is, throughout the taxation year, (a) a qualifying currency; and (b) the primary currency in which the taxpayer maintains its records and books of account for financial reporting purposes. ( monnaie fonctionnelle ) functional currency year of a taxpayer means a taxation year in respect of which subsection (5) applies to the taxpayer. ( année de déclaration en monnaie fonctionnelle ) pre-reversion debt of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first reversionary year. ( créance pré-rétablissement ) pre-transition debt of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first functional currency year. ( créance pré-transition ) qualifying currency at any time means each of (a) the currency of the United States of America; (b) the currency of the European Monetary Union; (c) the currency of the United Kingdom; (c.1) the currency of Japan; (d) the currency of Australia; and (e) a prescribed currency. ( monnaie admissible ) relevant spot rate , for a particular day, means, in respect of a conversion of an amount from a particular currency to another currency, (a) if the particular currency or the other currency is Canadian currency, the rate quoted by the Bank of Canada on the particular day (or, if the Bank of Canada ordinarily quotes such a rate, but there is no such rate quoted for the particular day, the closest preceding day for which such a rate is quoted) for the exchange of the particular currency for the other currency, or, in applying paragraphs (2)(b) and (5)(c), another rate of exchange that is acceptable to the Minister; and (b) if neither the particular currency nor the other currency is Canadian currency, the rate — calculated by reference to the rates quoted by the Bank of Canada on the particular day (or, if the Bank of Canada ordinarily quotes such rates, but either of such rates is not quoted for the particular day, the closest preceding day for which both such rates are quoted) for the exchange of Canadian currency for each of those currencies — for the exchange of the particular currency for the other currency, or, in applying paragraphs (2)(b) and (5)(c), another rate of exchange that is acceptable to the Minister. ( taux de change au comptant ) reversionary year of a taxpayer means a taxation year that begins after the last functional currency year of the taxpayer. ( année de rétablissement ) tax reporting currency of a taxpayer for a ta