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This is consistent with Justice Pinard's comments at page 6396 in the Federal Court-Trial Division case of Gaynor v The Queen [[1988] 2 C.T.C. 163] (88 DTC 6394), where he states: "... when the Income Tax Act, a Canadian statue, requires that a gain, a loss, a cost or a price be established or considered, that must be done in Canadian dollars at the relevant time, i.e. at the average exchange rate prevailing at the time such gain or loss occurs, and such cost or price is encountered. ...

As well, the "attributable to " concept thereunder will also have a significant impact. ...

Scenarios 2 & 3 With respect to the period throughout which the individual is not resident in Canada, section 115 is applicable but does not provide for the inclusion in income of any interest accrued during this period. ...

The question and answer was reviewed by John Kurrant, Oil & Gas Specialist on June 12 and he said that he does not have any concerns. ...

Former IT-436 contains comments in paragraphs 9 & 10 which, although not included in IT-436R due to the introduction of new 5 year time limit restrictions, are still considered relevant in some situations. ...

Yours truly, Chief Leasing & Financing Financial Industries Division Rulings Directorate ...

Yours truly, Section Chief Leasing & Financing Section Financial Industries Division Rulings Directorate Document Disclosed Pursuant to The Access To Information Act Document Divulgué en vertu de la loi sur l'accès à l'information ...

The Department made the following comments, which are still applicable to date, on this issue: "... ...

Carkner, of Client Assistance Directorate and further to a telephone conversation (Lisa Loyko Baker / Claude Tremblay) of March 17, 1992, regarding account holders, investment certificate holders and shareholders of XXX We were advised that all individual investors have recently received T5 slips. ...

We also refer to Olympia & York Developments Ltd. v The Queen, [[1980] C.T.C. 265] 80 DTC 6184(FCTB), at p. 6193. ...