II, s. 199, c. 21, s. 1161995, c. 21, s. 752007, c. 2, s. 54, c. 35, s. 662013, c. 34, s. 3652018, c. 27, s. 272021, c. 23, s. 64
261(1)The following definitions apply in this section.Canadian currency yearCanadian currency yearof a taxpayer means a taxation year that precedes the first functional currency year of the taxpayer. (année de déclaration en monnaie canadienne)Canadian tax resultsCanadian tax resultsof 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 currencyelected functional currencyof 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 currencyfunctional currencyof 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 yearfunctional currency yearof a taxpayer means a taxation year in respect of which subsection (5) applies to the taxpayer. (année de déclaration en monnaie fonctionnelle)pre-reversion debtpre-reversion debtof 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 debtpre-transition debtof 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 currencyqualifying currencyat 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;(d)the currency of Australia; and(e)a prescribed currency. (monnaie admissible)relevant spot raterelevant 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 yearreversionary yearof a taxpayer means a taxation year that begins after the last functional currency year of the taxpayer. (année de rétablissement)tax reporting currencytax reporting currencyof 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)Marginal note: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.Marginal note: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.Marginal note: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