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The general principles stated in this bulletin and established by the courts for foreign currency transactions are the following: a)     where the gain or loss arises in connection with the purchase or the sale of property or services, the nature of the gain and loss will be determined by the nature of the transaction.  ...

To the best of your knowledge, and that of the taxpayers involved, none of the issues contained herein: (i) is in an earlier return of the taxpayers or a related person; (ii) is being considered by a tax services office or taxation centre in connection with a previously filed tax return of the taxpayers or a related person; (iii) is under objection by the taxpayers or a related person; and (iv) is before the courts or, if a judgement has been issued, the time limit for appeal to a higher court has not expired. ...