CRA translates USD debt at the historical rate for thin cap purposes

CRA considers, based on s. 261(2), that the amount of U.S.-dollar denominated debt is to be measured for thin cap purposes in Canadian dollars based on the FX rate at the time the loan was made.

Neal Armstrong. Summary of 24 November 2015 CTF Annual Roundtable, Q. 10 under 2015 CTF Rountable.