IDTI » Topics » The Receipt of Canadian Currency

This excerpt taken from the IDTI 8-K filed May 20, 2009.

The Receipt of Canadian Currency

Canadian dollars received pursuant to the Arrangement will be included in the gross income of a U.S. Holder as translated into U.S. dollars calculated based on the exchange rate prevailing on the date of actual or constructive receipt of such Canadian dollars, regardless of whether the Canadian dollars are converted into U.S. dollars at that time. If the Canadian dollars received are not converted into U.S. dollars on the date of receipt, a U.S. Holder will have a basis in the Canadian dollars equal to their U.S. dollar value on the date of receipt. Any U.S. Holder who receives payment in Canadian dollars and engages in a subsequent conversion or other disposition of the Canadian dollars may have a foreign currency exchange gain or loss that would be treated as ordinary income or loss, and generally would be U.S. source income or loss for foreign tax credit purposes. U.S. Holders are urged to consult their own independent tax advisors concerning the U.S. tax consequences of acquiring, holding and disposing of Canadian dollars.

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