21.4.28. A pre-reversion debt of a taxpayer that is denominated in a currency other than Canadian currency is deemed to have been issued immediately before the taxpayer’s first reversionary year for the purpose of(a) computing the amount of the taxpayer’s income, gain or loss, for a reversionary year of the taxpayer (other than an amount that section 21.4.29 deems to arise), that is attributable to a fluctuation in the value of a currency; and
(b) applying subparagraph l of the first paragraph of section 485.3 in respect of a reversionary year of the taxpayer.