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Versions of s. 261(14)(b)

I-3.3 — Income Tax Act · 3 versions · View current text

Historical text comes from the Justice Laws point-in-time corpus and is unofficial — not the official version.

  1. 2017-12-14 to present available View Source
    where the taxpayer would have sustained a loss — or, if the pre-reversion debt was not on account of capital, would have had a loss — (referred to in this paragraph as the “hypothetical loss”) attributable to a fluctuation in the value of a currency if the pre-reversion debt had been settled by the taxpayer’s having paid, immediately before the end of its last functional currency year, an amount equal to the principal amount (expressed in the debt currency) at that time, the taxpayer is deemed to sustain or to have a loss in respect of the particular payment for the reversionary year equal to the amount that would be determined by the formula in paragraph (a) if the reference in the description of A in that paragraph to “hypothetical gain or income” were read as a reference to “hypothetical loss”.
    Full text

    where the taxpayer would have sustained a loss — or, if the pre-reversion debt was not on account of capital, would have had a loss — (referred to in this paragraph as the “hypothetical loss”) attributable to a fluctuation in the value of a currency if the pre-reversion debt had been settled by the taxpayer’s having paid, immediately before the end of its last functional currency year, an amount equal to the principal amount (expressed in the debt currency) at that time, the taxpayer is deemed to sustain or to have a loss in respect of the particular payment for the reversionary year equal to the amount that would be determined by the formula in paragraph (a) if the reference in the description of A in that paragraph to “hypothetical gain or income” were read as a reference to “hypothetical loss”.

  2. 2009-03-12 to 2017-12-14 View Source
    subsectionwhere (4)the istaxpayer deemedwould have sustained a loss — or, if the pre-reversion debt was not toon applyaccount of capital, would have had a loss — (referred to in this paragraph as the specified“hypothetical predecessorloss”) corporationattributable forto eacha taxationfluctuation yearin the value of a currency if the specifiedpre-reversion predecessordebt commencinghad afterbeen settled by the taxpayer’s having paid, immediately before the end of theits last functional currency yearyear, an amount equal to the principal amount (expressed in the debt currency) at that time, the taxpayer is deemed to sustain or to have a loss in respect of the specifiedparticular predecessorpayment describedfor the reversionary year equal to the amount that would be determined by the formula in paragraph (a).(a) if the reference in the description of A in that paragraph to “hypothetical gain or income” were read as a reference to “hypothetical loss”.
    Full text

    where the taxpayer would have sustained a loss — or, if the pre-reversion debt was not on account of capital, would have had a loss — (referred to in this paragraph as the “hypothetical loss”) attributable to a fluctuation in the value of a currency if the pre-reversion debt had been settled by the taxpayer’s having paid, immediately before the end of its last functional currency year, an amount equal to the principal amount (expressed in the debt currency) at that time, the taxpayer is deemed to sustain or to have a loss in respect of the particular payment for the reversionary year equal to the amount that would be determined by the formula in paragraph (a) if the reference in the description of A in that paragraph to “hypothetical gain or income” were read as a reference to “hypothetical loss”.

  3. 2007-12-14 to 2009-03-12 View Source

    subsection (4) is deemed not to apply to the specified predecessor corporation for each taxation year of the specified predecessor commencing after the end of the last functional currency year of the specified predecessor described in paragraph (a).