In the U.K., HMRC's guidance states that for as long as persons are resident in the U.K., the exchange tokens they hold as beneficial owner will be located in the U.K. Could CRA adopt a principle like that of the U.K. and treat the situs of cryptocurrencies as following that of the holder's residence? CRA responded:
The question of where a cryptocurrency is located, deposited or held within the meaning of section 233.3 is currently under review by the CRA.