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This translation was prepared by Tax Interpretations Inc. The CRA did not issue this document in the language in which it now appears, and is not responsible for any errors in its translation that might impact a reader’s understanding of it or the position(s) taken therein. See also the general Disclaimer below.
Principal Issues: When the use of an average rate would be acceptable and what would constitute an acceptable averaging period?
Position: Fundamental to the CRA’s acceptance of an average rate is whether it is reasonable to conclude that its use will still result in a reliable approximation of what a taxpayer’s income would have been using daily exchange rates.
Reasons: The appropriate and proper application of the CRA’s policy on the use of average exchange rates should be tax neutral and is not intended to provide any tax advantage.
FINANCIAL STRATEGIES AND FINANCIAL INSTRUMENTS ROUNDTABLE, 7 OCTOBER 2022
2022 APFF CONFERENCE
Q.3 - Average exchange rate
Subsection 261(2) provides the general rule that the currency to be used in computing "Canadian tax results" is the Canadian dollar. It also provides the mechanism by which amounts expressed in a foreign currency will be converted into Canadian dollars. Specifically, paragraph 261(2)(b) provides that any amount taken into account in computing Canadian tax results expressed in a currency other than Canadian dollars is converted to its Canadian dollar equivalent using the "spot rate of exchange" on the day it arose. The term "spot rate of exchange" for a particular day is defined in subsection 261(1) as the rate quoted by the Bank of Canada on that day, or such other rate of exchange as is acceptable to the Minister of National Revenue. Paragraph 1.6.1 of Income Tax Folio S5-F4-C1 (footnote 1) [CANADA REVENUE AGENCY, Income Tax Folio S5-F4-C1, "Income Tax Reporting Currency", February 27, 2019] indicates that the CRA may, for practical reasons, also accept a taxpayer's use of an average exchange rate over a period of time in order to convert certain income items that are relevant to the computation of income.
Question to the CRA
Can you elaborate on when it would be acceptable to use an average exchange rate and what constitutes an acceptable period for the use of an average rate?
CRA Response
The CRA's acceptance of the use of an average exchange rate for a period in certain circumstances emanates from a long-standing administrative policy established prior to the enactment of subsection 261(2). The purpose of this policy is to alleviate the administrative burden that could result from determining a series of daily exchange rates and multiple calculations for a taxpayer who has a significant stream of foreign currency transactions in a given period. While improvements in accounting software and other technologies have reduced the compliance burden associated with daily rate conversions, the CRA continues to apply its administrative policy. As explained in more detail below, the CRA's acceptance of an average rate is based on the fundamental principle that it must be reasonable to conclude that the use of the average rate will result in a fair approximation of the taxpayer's income as if the taxpayer had used daily exchange rates.
Consequently, for purposes of determining a taxpayer's income, the CRA will generally accept the use of an average exchange rate over a given period of time (e.g., annual, quarterly or monthly) to convert amounts arising from foreign currency transactions, if all of the following conditions are met:
- the amounts (as determined in foreign currency) are relatively stable and evenly distributed over the given period;
- the amounts arising in the particular period are sufficiently frequent that they do not distort income;
- the relevant exchange rate does not fluctuate significantly over the period; and
- the chosen approach is used consistently from year to year.
For example, if a taxpayer receives monthly interest payments in a foreign currency in an equal or similar amount in a taxation year, the CRA will generally accept the use of an average annual exchange rate to convert the amounts to Canadian dollars. However, if there are no transaction flows, or if there are very few transactions (e.g. annual, semi-annual or quarterly payments), the use of the applicable daily exchange rates will be required.
Disposition of capital property
As a general rule, the CRA will not accept the conversion of a gain or loss on the disposition of a capital property using an average exchange rate. A gain or loss is simply the arithmetic difference usually resulting from two or more separate transactions, a purchase and a sale, which generally occur on different dates. Consequently, the daily exchange rate for the particular dates should be used to determine, in Canadian dollars, the adjusted cost base ("ACB") of such property and any proceeds of disposition from its disposition.
Foreign currency held by an individual on capital account
As stated in Technical Interpretation 2014-0538631C6 (footnote 2), the use of an average exchange rate to compute capital gains and losses for the purposes of subsections 39(1) and 39(2) is not permitted. However, the CRA will generally accept an individual’s use of an average exchange rate to compute capital gains and losses pursuant to subsection 39(1.1) as a result of the disposition of foreign currency.
Fairness of the tax system is the fundamental principle from which the CRA's administrative policies emanate. An appropriate and fair application of a CRA policy on the use of average exchange rates must be tax neutral and must not provide any tax advantage. If the CRA determines that a taxpayer is abusing this administrative policy to gain a tax advantage, the CRA will compute the tax using the daily exchange rates for that and subsequent taxation years.
Sophie Larochelle
October 7, 2022
2022-093624
Response prepared in collaboration with:
James Atkinson, Coordinator, Industry Specialist Services - Financial Industry Section
Domestic Tax Division
International and Large Business Directorate
Compliance Programs Branch
Jess John, Acting Regional Senior Technical Advisor International Technical Issues Section
International Tax Division
International and Large Business Directorate
Compliance Programs Branch
FOOTNOTES
Note to reader: Because of our system requirements, the footnotes contained in the original document are shown below instead:
1 Canada Revenue Agency, Income Tax Folio S5-F4-C1, "Reporting Currency", February 27, 2019
2 Canada Revenue Agency, Technical Interpretation 2014-0538631C6, October 10, 2014
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