Income Tax Act — I-3.3 261
y 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 amount from the particular currency to the taxpayer’s elected functional currency, or a rate of exchange acceptable to the Minister; (e) except in applying paragraph 95(2)(f.15) in respect of a taxation year, of a foreign affiliate of the taxpayer, that is a functional currency year of the foreign affiliate within the meaning of subsection (6.1), each reference in subsection 39(2) to “Canadian currency” is to be read, in respect of the taxpayer and the particular taxation year, and with such modifications as the context requires, as a reference to “the taxpayer’s elected functional currency”; (f) each reference in (i) section 76.1, subsections 20(14.2) and 79(7), paragraph 80(2)(k), subsections 80.01(11), 80.1(8), 93(2.01) to (2.31), 142.4(1) and 142.7(8) and the definition amortized cost in subsection 248(1), and subparagraph 231(6)(a)(iv) of the Income Tax Regulations , to “Canadian currency” is, in respect of the taxpayer and the particular taxation year, and with such modifications as the context requires, to be read as “the taxpayer’s elected functional currency”, and (ii) subparagraph 94.1(1)(b)(vii), the definition foreign currency debt in subsection 111(8), subsection 142.4(1), and the definition amortized cost in subsection 248(1) to “currency of a country other than Canada” is, in respect of the taxpayer and the particular taxation year, and with such modifications as the context requires, to be read as a reference to “currency other than the taxpayer’s elected functional currency”; (g) the definition foreign currency in subsection 248(1) is, in respect of the taxpayer and the taxation year, and with such modifications as the context requires, to be read as follows: foreign currency in respect of a taxpayer, at any time in a taxation year, means a currency other than the taxpayer’s elected functional currency; (h) where a taxation year, of a foreign affiliate of the taxpayer, is a functional currency year of the foreign affiliate within the meaning of subsection (6.1), (i) the references in section 95 (other than paragraph 95(2)(f.15)) and the references in regulations made for the purposes of section 95 or 113 to (A) “Canadian currency” are to be read, in respect of the foreign affiliate and the taxation year, and with such modifications as the context requires, as references to “the taxpayer’s elected functional currency”, and (B) “currency of a country other than Canada” are to be read, in respect of the foreign affiliate and the taxation year, and with such modifications as the context requires, as references to “currency other than the taxpayer’s elected functional currency”, and (ii) the reference in paragraph 95(2)(f.13) to “the rate of exchange quoted by the Bank of Canada on” is to be read, in respect of the foreign affiliate and the taxation year, and with such modifications as the context requires, as a reference to “the relevant spot rate for”. Partnerships (6) For the purposes of computing the Canadian tax results of a 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 each partnership of which the particular taxpayer is a member at any time in the taxation year were a taxpayer that (a) had as its first functional currency year its first fiscal period, if any, that (i) is a fiscal period at any time during which the particular taxpayer is a member of the partnership, (ii) begins after December 13, 2007, and (iii) begins on or after the first day of the particular taxpayer’s first functional currency year; (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