2 November 2023 APFF Roundtable Q. 9, 2023-0982911C6 - APFF - Congrès 2023 - Table ronde sur la fiscalité -- summary under Paragraph (b)

Madame Y made a cash purchase of a bitcoin on a central exchange platform in order that she could ultimately pay for items online. Subsequently, in 2023, the exchange platform was the victim of fraud and Madame Y lost access to her bitcoin. In the course of discussing the character and timing of her loss, CRA indicated that although a loss from fraud usually arises when the loss is recognized, “where the taxpayer has received compensation for capital property unlawfully taken, the specific rules of subsection 44(2) apply to determine the time of disposition.”