Amicarelli – Tax Court of Canada finds that an individual’s loss through fraud of her Bitcoin was on income account

The taxpayer, an Air Canada employee, purchased over 100 Bitcoin in 2017 through the cryptocurrency exchange QuadrigaCX, whose “co-founder and CEO … was most likely a fraudster who misused client assets”. Her account balance vanished in December 2017, resulting in a total loss.

Before concluding that her loss was deductible in computing her income for 2017, Sorensen J. found inter alia 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”; and
• the Bitcoin did not generate any income, such as interest, dividends, or distributions; and there was no personal use or benefit.

Neal Armstrong. Summary of Amicarelli v. The King, 2025 TCC 185 under s. 9 – capital gain v. profit – cryptocurreny, and General Concepts – Evidence.