Regarding whether s. 39(1.1) did not extend (as indicated in 2017-0712621C6 F) to dispositions of foreign currencies held on deposit at a financial institution by an individual rather than being restricted to bills or coins, CRA noted that, in addition to a more technical meaning, “currency” also could refer “simply to ‘money’ that is used in a country, with the definition of ‘money’ including sums in a bank account,” and that “it is relevant to consider that subsection 39(1.1) does not apply to a specialized audience,” e.g., it could apply to an individual “using foreign currency on a holiday in a foreign country,” the Directorate stated:
[I]n the context of subsection 39(1.1), the phrase “dispositions of currency other than Canadian currency” includes situations where foreign currency funds in a chequing or current deposit account, which entitles the depositor to withdraw the currency on deposit at any time, are converted into another currency or used to make a purchase or a payment.
Where s, 39(1.1) did not apply to a disposition of capital property, s. 39(1) would apply (and not s. 39(2), which applies to FX-denominated obligations).