Income Tax Act — I-3.3 261
t ) 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 taxation year, and at any time in the taxation year, means the currency in which the taxpayer’s Canadian tax results for the taxation year are to be determined. ( monnaie de déclaration ) Canadian currency requirement (2) In determining the Canadian tax results of a taxpayer for a particular taxation year, (a) subject to this section, other than this subsection, Canadian currency is to be used; and (b) subject to this section, other than this subsection, subsections 20(14.2) and 79(7) and paragraphs 80(2)(k) and 142.7(8)(b), if a particular amount that is relevant in computing those Canadian tax results is expressed in a currency other than Canadian currency, the particular amount is to be converted to an amount expressed in Canadian currency using the relevant spot rate for the day on which the particular amount arose. Application of subsection (5) (3) Subsection (5) applies to a taxpayer in respect of a particular taxation year if (a) the taxpayer is, throughout the particular taxation year, a corporation (other than an investment corporation, a mortgage investment corporation or a mutual fund corporation) resident in Canada; (b) the taxpayer has elected that subsection (5) apply to the taxpayer and has filed that election with the Minister in prescribed form and manner on or before the day that is 60 days after the first day of the particular taxation year; (c) there is a functional currency of the taxpayer for the first taxation year of the taxpayer in respect of which subsection (5) would, if this subsection were read without reference to this paragraph, apply; (d) the taxpayer has not filed another election under paragraph (b); and (e) a revocation by the taxpayer under subsection (4) does not apply to the particular taxation year. Revocation of election (4) A taxpayer may revoke its election under paragraph (3)(b) by filing, on a day that is in a functional currency year of the taxpayer (other than its first functional currency year), a notice of revocation in prescribed form and manner. The revocation applies to each taxation year of the taxpayer that begins on or after the day that is six months after that day. Functional currency tax reporting (5) If this subsection applies to a taxpayer in respect of a particular taxation year, (a) the taxpayer’s Canadian tax results for the particular taxation year are to be determined using the taxpayer’s elected functional currency; (b) unless the context otherwise requires, each reference in this Act or the regulations to an amount (other than in respect of a penalty or fine) that is described as a particular number of Canadian dollars is to be read, in respect of the taxpayer and the particular taxation year, as a reference to that amount expressed in the taxpayer’s elected functional currency using the relevant spot rate for the first day of the particular taxation year; (c) subject to paragraph (9)(b), subsection (15), subsections 20(14.2) and 79(7) and paragraphs 80(2)(k) and 142.7(8)(b), if a particular amount that is relevant in computing the taxpayer’s Canadian tax results for the particular taxation year is expressed in a currency other than the taxpayer’s elected functional currency, the particular amount is to be converted to an amount expressed in the taxpayer’s elected functional currency using the relevant spot rate for the day on which the particular amount arose; (d) the definition exchange rate in subsection 111(8) is, in respect of the taxpayer and the particular taxation year, and with such modifications as the context requires, to be read as follows: exchange rate at any time in respect of a particular currency other than the taxpayer’s elected functional currency means the relevant spot rate, for the day that includes that time, in respect of the conversion of an a