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ARTICLE · 29 OCTOBER 2026

Cryptocurrency Held Through A Bare Trustee: Tax Treatment And The 2026 Reporting Obligations

Rotfleisch & Samulovitch P.C.
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If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.

CanadaTax
David Rotfleisch
David Rotfleisch
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Published: April 14, 2022
Last Updated: October 22, 2026

Current to October 22, 2026. Dates for the Crypto-Asset Reporting Framework depend on Bill C-31 as enacted.

Overview: Bare Trusts and Canadian Cryptocurrency Holders

If you hold cryptocurrency, NFTs or other blockchain assets in someone else’s wallet, or hold assets in your own wallet for someone else, the arrangement is very likely a bare trust. Until recently, that carried almost no compliance consequence. It now carries three reporting obligations to track: the T3 filing for 2026, the T1135, and the proposed Crypto-Asset Reporting Framework from 2027.

This article explains what a bare trust is, how it is taxed when the property is a digital asset, how to tell whether one exists, and what must now be filed. The reporting position has changed materially since this article was first published, and the change runs against the taxpayer.

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The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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