19 April 1990 T.I. (September 1990 Access Letter, ¶1414)

Where the Canadian partners of a U.S. partnership enter into currency feature contracts to close on the anticipated date of distribution of income in U.S. dollars from the partnership and convert the U.S. dollar distribution received to Canadian dollars upon receipt, the exchange rate that will govern for purposes of the adjustment to the ACB of the partnership interest will be that prevailing at the time they receive the distribution. The hedge transaction will be considered to be a separate transaction.

Where Canadian residents, who are members of a partnership doing business in the U.S., enter into currency futures contracts to close on the anticipated date of distributions from the U.S. partnership in U.S. dollars, the hedge transaction will be considered to be a separate transaction from the distribution, and the hedge transaction will be characterized as a capital transaction if the partners hold their partnership interests as capital property and are not in the business of buying and selling currency futures contracts - unless they have elected as subscribed in IT-95R, para. 6.