Does s. 39(1.1), which applies to dispositions by an individual of foreign currency banknotes or coins, extend to dispositions of foreign currency held by an individual on deposit at a financial institution? CRA noted that in 2020-0868031I7:
Based on a textual, contextual and purposive interpretation of subsection 39(1.1), we concluded that the phrase “dispositions of currency other than Canadian currency” in that subsection includes dispositions of foreign currency held by an individual in a chequing or current deposit account at a financial institution, to the extent that the individual is entitled to withdraw the currency on deposit at any time, convert it into another currency at any time, or use it to make a purchase or a payment at any time.