When Canadian multinationals issue discounted bonds, notes and similar obligations in a foreign currency, the tax consequences of repaying the debt are governed by subsections 39(2) and paragraph 20(1)(f) of the Income Tax Act (Canada). Jared Mackey and Anu Nijhawan explore the application and interaction of these provisions, which can give rise to unexpected results, in an article entitled The Repayment of Discounted Foreign Currency Obligations, published byThe Federated Press International Tax Planning newsletter (Volume XXVIII No. 1), which can be accessed on Taxnet Pro by Thomson Reuters.
Bennett Jones