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ARTICLE · 28 NOVEMBER 2023

CRA Provides Guidance On Crypto Taxation Issues At APFF Roundtable

McCarthy Tétrault
McCarthy Tétrault
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In early November 2023, the Canada Revenue Agency (CRA) participated in a roundtable with the Association de planification fiscale et financière (APFF), during which they commented on various issues regarding the taxation of cryptocurrencies.

CanadaTechnology
Tax Perspectives
Tax Perspectives
Lori Stein
Lori Stein
Mike Dolson
Mike Dolson
GenevièVe Favreau
GenevièVe Favreau
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In early November 2023, the Canada Revenue Agency (CRA) participated in a roundtable with the Association de planification fiscale et financière (APFF), during which they commented on various issues regarding the taxation of cryptocurrencies. The CRA's comments are welcome, as they provide useful administrative guidance in areas of uncertainty for cryptocurrency users and intermediaries.

The CRA was presented with a fact pattern where a taxpayer holding bitcoins in a cryptocurrency wallet for which the taxpayer is the only one to control the private key transfers the bitcoins to a centralized platform for exchanging and lending crypto assets, as a "deposit" of the bitcoins (i.e., a loan of the specific property). The platform offers the taxpayer a variable return of about 4% per year payable in bitcoin in return for the deposit. The platform's terms of service provide that the platform has the right to pledge, sell, or lend the bitcoins, and any profit made from

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