Prior to the October 10, 2022 release by the OECD of its Crypto-Asset Reporting Framework and Amendments to the Common Reporting Standard, CRA stated:
Given the decentralized nature of cryptocurrency, the question of where a cryptocurrency is located, deposited or held within the meaning of section 233.3 is complex. This issue is still under active consideration by the CRA.
… [C]rypto-assets, by their very nature, are more difficult to track than traditional assets. Consequently, they carry a material risk of tax evasion or non-compliance, regardless of their situs. The CRA believes that, in general, reporting of crypto-assets would facilitate tax compliance in this growing sector. The CRA is currently considering several options, including changes to certain forms, schedules and guides that would increase disclosure for this type of asset and promote tax compliance.