In the case of foreign-currency denominated stripped coupon, could CRA accept the use of an average exchange rate for the conversion into Canadian dollars of the accrued interest which is deemed to accrue pursuant to ss. 12(3), (4) and (9)?
CRA indicated that, given the steady and day-to-day accrual of the interest amounts to be translated, the first two of its four conditions for an average exchange rate would be satisfied, namely, that the foreign currency amounts “are relatively stable and evenly distributed” and “are sufficiently frequent and spread out” to avoid distortion. Regarding satisfaction of the third condition (“the relevant exchange rate does not fluctuate significantly over the period”), that would require an assessment of the impact of the exchange rate differences on the amount to be converted.
Regarding the fourth condition (“the average rate is the rate used by the taxpayer each time these conditions are met”), CRA noted:
The existence of a difference in exchange rates having a significant impact on the converted amount, such that the third condition above is not satisfied during a given period and preventing the use of the average rate during that period, would not affect the use of the average rate to the extent that the average rate is used during all prior and subsequent periods during which the third condition is satisfied.