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...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 9 - Capital Gain vs. Profit - Cryptocurrency | lack of income on bitcoins suggested that they might be acquired on income account | 245 |
| Tax Topics - Income Tax Act - Section 54 - Adjusted Cost Base | property acquired on income account does not have an ACB | 99 |
| Tax Topics - Income Tax Act - Section 9 - Computation of Profit | exchange of right to receive 740 unallocated bitcoin subject to other creditors’ rights treated as giving rise to gain based on the value of the bitcoin received on the exchange | 128 |
9 October 2025 APFF Roundtable Q. 12, 2025-1071531C6 F - Confirmer le traitement fiscal des Simple Agreement for Future Equity
A SAFE (Simple Agreement for Future Equity) is a financing agreement in which an investor provides funds to a company in exchange for the right to...
| Locations of other summaries | Wordcount | |
|---|---|---|
| Tax Topics - Income Tax Act - Section 51 - Subsection 51(1) | SAFE likely is not a share, or a bond, debenture or note | 268 |
| Tax Topics - Income Tax Act - Section 12 - Subsection 12(11) - Investment Contract | conditional contractual obligation to issue shares likely was not a bond, debenture or note | 201 |