Please note that the following document, although correct at the time of issue, may not represent the current position of the Canada Revenue Agency. / Veuillez prendre note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'Agence du revenu du Canada.
GST/HST Rulings Directorate
Place de Ville, Tower A, 11th floor
320 Queen Street
Ottawa ON K1A 0L5
[Addressee]
Case Number: 236273
Dear [Client]:
Subject: GST/HST INTERPRETATION
[Adjustments to previous returns -] […] foreign currency conversion
Thank you for your email received on [mm/dd/yyyy], where you requested our opinion concerning various requests made by […][a registrant].
[INTERPRETATION REQUESTED]
[…][You ask if a registrant can adjust] previously filed net tax returns arising from […][foreign currency] transactions by using the day the GST/HST is payable for converting the value of the consideration for a supply into Canadian currency pursuant to section 159 of the ETA or by using another day acceptable to the Minster as described in GST/HST Memorandum 3.6, Conversion of Foreign Currency, provided the method used is applied consistently for a period of at least one year.
You are also asking whether the CRA can deny or amend previous net tax adjustments where […][a registrant] used a foreign conversion method that is not the day the GST/HST is payable nor a method listed in GST/HST Memorandum 3.6 and where […][the registrant] did not submit a written request to Excise and GST/HST Rulings Directorate to obtain the Minister’s approval to use such a method in advance of its use.
[INTERPRETATION GIVEN]
With respect to retroactively adjusting the method for converting the value of consideration, […], [a registrant] may request an adjustment to its previously filed net tax returns within four years after the later of the day the return was filed and the due date of the return. For a particular reporting period(s) being adjusted, [the registrant] may use the exchange rate on the day the GST/HST was payable to convert the value of the consideration for a supply into Canadian currency pursuant to section 159 or by using another day acceptable to the Minster as described in GST/HST Memorandum 3.6 provided the method used is applied consistently for a period of at least one year.
[…].
[In accordance with the qualifications and guidelines set out in GST/HST Memorandum 1.4, Excise and GST/HST Rulings and Interpretations Service, the interpretation given in this letter is not a ruling and does not bind the Canada Revenue Agency (CRA) with respect to a particular situation. Future changes to the ETA, regulations, or the CRA’s interpretative policy could affect the interpretation provided herein.]
If you require clarification with respect to any of the issues discussed in this letter, please contact me at 819-271-8709.
Joseph Zeidan
Senior Rulings Officer
General Operations and Border Issues Division
GST/HST Rulings Directorate
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