27 June 2011 External T.I. 2009-0350501E5 F - Gains et pertes sur change étranger -- summary under Paragraph (a)

A Canadian corporation acquires capital property at a cost of U.S.$90,000 and pays the purchase price 30 days later after the exchange rate has moved from Cdn.$1.10 to Cdn.$1.11. After concluding that this resulted in a capital loss of $900 under s. 39(2), CRA stated:

As stated in 2007-0234691I7, the capital gain or loss arising from the application of subsection 39(2) can only be determined at the end of the taxpayer's taxation year and only after considering all foreign exchange gains/losses realized/incurred in that taxation year. Consequently, the capital gains or losses resulting from subsection 39(2) will only affect the balance of the capital dividend account at the end of the taxpayer's taxation year.

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d7 import status
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