17 January 1991 T.I. (Tax Window, Prelim. No. 3, p. 2, ¶1094)

Accrued foreign exchange gains or losses on foreign currency deposits will not be considered to have been made or sustained until the funds are converted into another currency or are used to purchase a negotiable instrument or some other asset.

The interest income of a controlled foreign affiliate on a foreign currency deposit denominated in a currency which was depreciating rapidly relative to the Canadian dollar was to be measured on the basis of the average exchange rate for the year, without deduction for the accrued foreign exchange loss on the deposit, in light of the fact that s. 39(2) govern the recognition of foreign exchange losses on capital account.