Income Tax Act — I-3.3 261
ear; (b) had as its last Canadian currency year its last fiscal period, if any, that ends before its first functional currency year; (c) had as its first reversionary year its first fiscal period, if any, that begins after the particular taxpayer’s last functional currency year; (d) is subject to subsection (5) for each of its fiscal periods that is, or begins after, its first functional currency year and that ends before its first reversionary year; (e) had as its elected functional currency in respect of each fiscal period described in paragraph (d) the elected functional currency of the particular taxpayer; and (f) had as its last functional currency year its last fiscal period, if any, that ends before its first reversionary year. Foreign affiliates (6.1) For the purposes of computing the foreign accrual property income of a foreign affiliate of a particular taxpayer, in respect of the particular taxpayer, for each taxation year that is a functional currency year or a reversionary year of the particular taxpayer, this section is to be applied as if (a) the foreign affiliate were a taxpayer that (i) had, as its first functional currency year, its first taxation year that (A) is a taxation year at any time during which the foreign affiliate is a foreign affiliate of the particular taxpayer, (B) begins after December 13, 2007, and (C) begins on or after the first day of the particular taxpayer’s first functional currency year, (ii) had as its last Canadian currency year its last taxation year, if any, that ends before its first functional currency year, (iii) had as its first reversionary year its first taxation year, if any, that begins after the particular taxpayer’s last functional currency year, (iv) is subject to subsection (5) for each of its taxation years that is, or begins after, its first functional currency year and that ends before its first reversionary year, (v) had as its elected functional currency in respect of each taxation year described in subparagraph (iv) the elected functional currency of the particular taxpayer, and (vi) had as its last functional currency year its last taxation year, if any, that ends before its first reversionary year; and (b) the Canadian tax results of the foreign affiliate for each taxation year that is a functional currency year or a reversionary year of the foreign affiliate, within the meaning of paragraph (a), were its foreign accrual property income, in respect of the particular taxpayer, for that taxation year and any amount that is relevant in determining such foreign accrual property income. Converting Canadian currency amounts (7) In applying this Act to a taxpayer for a particular functional currency year of the taxpayer, the following amounts are to be converted from Canadian currency to the taxpayer’s elected functional currency using the relevant spot rate for the last day of the taxpayer’s last Canadian currency year: (a) each particular amount that (i) is, or is relevant to the determination of, an amount that may be deducted under subsection 37(1) or 66(4), variable F or F.1 in the definition foreign accrual property income in subsection 95(1), section 110.1 or 111 or subsection 126(2), 127(5), 129(1), 181.1(4) or 190.1(3), in the particular functional currency year, and (ii) was determined for a Canadian currency year of the taxpayer; (b) the cost to the taxpayer of a property that was acquired by the taxpayer in a Canadian currency year of the taxpayer; (c) an amount that was required by section 53 to be added or deducted in computing, at any time in a Canadian currency year of the taxpayer, the adjusted cost base to the taxpayer of a capital property that was acquired by the taxpayer in such a year; (d) an amount that (i) is in respect of the taxpayer’s undepreciated capital cost of depreciable property of a prescribed class, cumulative Canadian exploration expense (as defined in subsection 66.1(6)), cumulative Canadian development expense (as defined in subsect