In determining that the treatment of a cash premium paid by the taxpayer in settling an exchangeable debenture issued by a predecessor should be determined in accordance with a pre-2010 policy of CRA, the Directorate stated:
This is consistent with the Agency's normal practice when revising an interpretation or position in a Bulletin, where the new interpretation or position is not to the benefit of taxpayers, it will generally apply only to the taxation year of the change and subsequent taxation years, or it will apply to transactions entered into after the date of the announcement of the change.