I-3 - Taxation Act

Section 21.4.16 Disposition versions

2021-06-02

21.4.16. In this chapter,

“Canadian currency year” of a taxpayer means a taxation year that precedes the first functional currency year of the taxpayer;

“elected functional currency” of a taxpayer means the currency of a country other than Canada that is the elected functional currency of the taxpayer, within the meaning of subsection 1 of section 261 of the Income Tax Act (R.S.C. 1985, c. 1 (5th Suppl.)), for the purposes of that section;

“functional currency year” of a taxpayer means a taxation year in respect of which the rules set out in section 21.4.19 apply to the taxpayer;

“pre-reversion debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first reversionary year;

“pre-transition debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first functional currency year;

“Québec tax results” of a taxpayer for a taxation year means

(a)  the amount of the income, taxable income or taxable income earned in Canada of the taxpayer for the taxation year, or any other amount used as a basis for computing an amount that the taxpayer is required to pay for the taxation year under this Act, other than under Part III.7 or III.7.0.1 (except for the purposes of section 21.4.17);

(b)  the amount (other than an amount payable on behalf of another person under section 1015 or, except for the purposes of section 21.4.17, other than an amount payable under Part III.7 or III.7.0.1) of tax or any other amount payable under this Act by the taxpayer in respect of the taxation year;

(c)  the amount (other than an amount refundable on behalf of another person in respect of amounts payable on behalf of that person under section 1015) of tax or any other amount refundable under this Act to the taxpayer in respect of the taxation year; and

(d)  any amount (including an amount provided for in Chapter V of the Act respecting international financial centres (chapter C-8.3)) that is relevant in computing the amounts described in respect of the taxpayer in paragraphs a to c;

“relevant spot rate” for a particular day means, in respect of a conversion of an amount from a particular currency to another currency,

(a)  if the particular currency or the other currency is Canadian currency, the rate quoted by the Bank of Canada on the particular day (or, if the Bank of Canada ordinarily quotes such a rate, but there is no such rate quoted for the particular day, the closest preceding day for which such a rate is quoted) for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister; and

(b)  if neither the particular currency nor the other currency is Canadian currency, the rate—calculated by reference to the rates quoted by the Bank of Canada on the particular day (or, if the Bank of Canada ordinarily quotes such rates, but either of such rates is not quoted for the particular day, the closest preceding day for which both such rates are quoted)—for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister;

“reversionary year” of a taxpayer means a taxation year that begins after the last functional currency year of the taxpayer;

“tax reporting currency” of a taxpayer for a taxation year, and at any time in the taxation year, means the currency in which the taxpayer’s Québec tax results for the taxation year are to be computed.

2010, c. 5, s. 11; 2017, c. 1, s. 79; 2021, c. 14, s. 21.

2017-02-08

21.4.16. In this chapter,

“Canadian currency year” of a taxpayer means a taxation year that precedes the first functional currency year of the taxpayer;

“elected functional currency” of a taxpayer means the currency of a country other than Canada that is the elected functional currency of the taxpayer, within the meaning of subsection 1 of section 261 of the Income Tax Act (R.S.C. 1985, c. 1 (5th Suppl.)), for the purposes of that section;

“functional currency year” of a taxpayer means a taxation year in respect of which the rules set out in section 21.4.19 apply to the taxpayer;

“pre-reversion debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first reversionary year;

“pre-transition debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first functional currency year;

“Québec tax results” of a taxpayer for a taxation year means

(a)  the amount of the income, taxable income or taxable income earned in Canada of the taxpayer for the taxation year, or any other amount used as a basis for computing an amount that the taxpayer is required to pay for the taxation year under this Act, other than under Part III.7 or III.7.0.1 (except for the purposes of section 21.4.17);

(b)  the amount (other than an amount payable on behalf of another person under section 1015 or, except for the purposes of section 21.4.17, other than an amount payable under Part III.7 or III.7.0.1) of tax or any other amount payable under this Act by the taxpayer in respect of the taxation year;

(c)  the amount (other than an amount refundable on behalf of another person in respect of amounts payable on behalf of that person under section 1015) of tax or any other amount refundable under this Act to the taxpayer in respect of the taxation year; and

(d)  any amount (including an amount provided for in Chapter V of the Act respecting international financial centres (chapter C-8.3)) that is relevant in computing the amounts described in respect of the taxpayer in paragraphs a to c;

“relevant spot rate” for a particular day means, in respect of a conversion of an amount from a particular currency to another currency,

(a)  if the particular currency or the other currency is Canadian currency, the rate quoted by the Bank of Canada for noon on the particular day (or, if there is no such rate quoted for the particular day, the closest preceding day for which such a rate is quoted) for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister; and

(b)  if neither the particular currency nor the other currency is Canadian currency, the rate—calculated by reference to the rates quoted by the Bank of Canada for noon on the particular day (or, if either of such rates is not quoted for the particular day, the closest preceding day for which both such rates are quoted)—for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister;

“reversionary year” of a taxpayer means a taxation year that begins after the last functional currency year of the taxpayer;

“tax reporting currency” of a taxpayer for a taxation year, and at any time in the taxation year, means the currency in which the taxpayer’s Québec tax results for the taxation year are to be computed.

2010, c. 5, s. 11; 2017, c. 1, s. 79.

2010-04-20

21.4.16. In this chapter,

“Canadian currency year” of a taxpayer means a taxation year that precedes the first functional currency year of the taxpayer;

“elected functional currency” of a taxpayer means the currency of a country other than Canada that is the elected functional currency of the taxpayer, within the meaning of subsection 1 of section 261 of the Income Tax Act (R.S.C. 1985, c. 1 (5th Suppl.)), for the purposes of that section;

“functional currency year” of a taxpayer means a taxation year in respect of which the rules set out in section 21.4.19 apply to the taxpayer;

“pre-reversion debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first reversionary year;

“pre-transition debt” of a taxpayer means a debt obligation of the taxpayer that was issued by the taxpayer before the beginning of the taxpayer’s first functional currency year;

“Québec tax results” of a taxpayer for a taxation year means

(a)  the amount of the income, taxable income or taxable income earned in Canada of the taxpayer for the taxation year, or any other amount used as a basis for computing an amount that the taxpayer is required to pay for the taxation year under this Act, other than under Part III.7 (except for the purposes of section 21.4.17);

(b)  the amount (other than an amount payable on behalf of another person under section 1015 or, except for the purposes of section 21.4.17, other than an amount payable under Part III.7) of tax or any other amount payable under this Act by the taxpayer in respect of the taxation year;

(c)  the amount (other than an amount refundable on behalf of another person in respect of amounts payable on behalf of that person under section 1015) of tax or any other amount refundable under this Act to the taxpayer in respect of the taxation year; and

(d)  any amount (including an amount provided for in Chapter V of the Act respecting international financial centres (chapter C-8.3)) that is relevant in computing the amounts described in respect of the taxpayer in paragraphs a to c;

“relevant spot rate” for a particular day means, in respect of a conversion of an amount from a particular currency to another currency,

(a)  if the particular currency or the other currency is Canadian currency, the rate quoted by the Bank of Canada for noon on the particular day (or, if there is no such rate quoted for the particular day, the closest preceding day for which such a rate is quoted) for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister; and

(b)  if neither the particular currency nor the other currency is Canadian currency, the rate—calculated by reference to the rates quoted by the Bank of Canada for noon on the particular day (or, if either of such rates is not quoted for the particular day, the closest preceding day for which both such rates are quoted)—for the exchange of the particular currency for the other currency, or, for the purposes of paragraph b of section 21.4.17 and paragraph c of section 21.4.19, any other rate of exchange that is acceptable to the Minister;

“reversionary year” of a taxpayer means a taxation year that begins after the last functional currency year of the taxpayer;

“tax reporting currency” of a taxpayer for a taxation year, and at any time in the taxation year, means the currency in which the taxpayer’s Québec tax results for the taxation year are to be computed.

2010, c. 5, s. 11.