See Also
Amicarelli v. The King, 2025 TCC 185
The taxpayer, who was a full-time Air Canada employee with an annual employment income of under $100,000, purchased over 100 Bitcoin in 2017 through the cryptocurrency exchange QuadrigaCX. However, her account balance vanished in December 2017 due to suspected fraud (“the co-founder and CEO of QuadrigaCX, Gerald Cotten, was most likely a fraudster who misused client assets” (para. 31)), resulting in a loss of around $473,000.
Before concluding that her loss was deductible in computing her income for 2017, Sorensen J. found that:
- she had purchased her Bitcoin with a view to profit
- her regular purchases and routine engagement in monitoring of the account and the market were “more then dabbling and were more akin to activities of a trader or dealer” (para. 49)
- the Bitcoin did not generate any income, such as interest, dividends, or distributions and, in this case, there was no personal use or benefit.
- her financing activities, such as the use of credit cards and withdrawals from her RRSP and taking out a second mortgage, “were very costly” (para. 55).
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - General Concepts - Evidence | OSC report accepted under public documents exception | 98 |
Administrative Policy
10 September 2025 External T.I. 2025-1070171E5 F - Disposition of a right to receive bitcoins
In 2014, a Canadian resident acquired from an unrelated insolvent foreign corporation the right to receive 740 bitcoins in consideration for a payment of 75 bitcoins. Ten years later, after the winding-up process for the non-resident corporation was completed, the taxpayer received 115.2602 bitcoins in settlement of the entitlement to receive 740 bitcoins.
Regarding whether this transaction was an adventure in the nature of trade, CRA indicated that Meronek and Dally (finding that debts, owing by corporations in financial difficulty, that were acquired for nominal amounts gave rise to profits from adventures in the nature of trade on their repayment as they did not have the characteristics of an investment) “were worth mentioning.” CRA further stated that a long holding period did not preclude an asset from having been acquired in connection with an adventure in the nature of trade, provided that the taxpayer's intention was always to resell the asset at a profit rather than to make a long-term investment.
Here, CRA noted as relevant that the right to receive the bitcoins was not likely to generate income during the period of ownership. Additionally, the 10-year holding period might have corresponded to the time required to complete the winding-up process rather than reflecting an intention to retain the right in the long term.
However, CRA did not conclude as to whether the gains were business income or capital gains.
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | property acquired on income account does not have an ACB | 99 |