What will CRA accept as “another rate of exchange that is acceptable to the Minister” under the relevant spot rate definition? CRA responded:
- The Minister will generally accept a rate quoted by another source [rather than the daily rate quoted by the Bank of Canada] provided it is:
- widely available;
- verifiable;
- published by an independent provider on an ongoing basis [e.g., Bloomberg L.P., Thomson Reuters Corporation and OANDA Corporation, whose rates are "generally acceptable"]; …
- used in accordance with well-accepted business principles;
- used for the preparation of the taxpayer’s financial statements; and
- used consistently from year to year by the taxpayer. ...
- The Bank of Canada rate will still be required in respect of a taxpayer transitioning into or out of income tax reporting in its elected functional currency in accordance with subsections 261(7) or 261(12)... .