Eric Bretsen, Heather Kerr, "Tax Planning for Foreign Currency", 2009 Conference Report (CTF), C. 35.

Summary Under
Tax Topics - Income Tax Act - Section 261 - Subsection 261(1) - Functional Currency
Removal in new definition of principal business and consolidated financial statement requirements (pp. 35:32-33)

The new definition removed the...

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Summary Under
Tax Topics - Income Tax Act - Section 261 - Subsection 261(18)
Carve-out for commerical transactions

Although this provision is now a broadly applicable anti-abuse rule, it contains a dual-step carve-out for...

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Summary Under
Tax Topics - Income Tax Act - Section 261 - Subsection 261(20)
Loss denial arising where U.S. commercial paper issued through U.S. sub (pp. 35:42-43)

Canco…uses the Canadian dollar as its functional...

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