CRA directs dual-currency filing of s. 85 elections where the transferor and transferee have different tax reporting currencies

CRA indicated that where the parties to a s. 85 rollover transaction have different tax reporting currencies (as defined in s. 261(1)), it would require that two separate forms T2057 be filed. The amounts would be reported and denominated in the transferor’s tax reporting currency on the first form T2057, and in the transferee’s tax reporting currency on the second T2057.

Neal Armstrong. Summary of 15 September 2020 IFA Roundtable, Q.1 under s. 85(1).