In return for depositing the taxpayer’s bitcoins with a centralized cryptoasset exchange and lending platform, the latter offers the taxpayer a variable return of approximately 4% per annum, payable in bitcoin. The platform holds the bitcoins in its own name and may pledge, sell or lend the bitcoins deposited in the account in its discretion without informing the taxpayer. The profit derived from the use of the bitcoins by the platform is its property and not the taxpayer’s. The taxpayer is entitled to withdraw up to an equivalent of the taxpayer’s bitcoin account balance at any time, with withdrawal being paid from a cryptocurrency wallet in which the bitcoins received from the platform's various customers are collectively deposited.
In finding that there likely was a disposition on the bitcoin transfer to the platform, CRA indicated that it was “likely that ownership of the bitcoins initially belonging to the taxpayer was transferred to the platform” and, in particular, that “the platform acquired the right to use the assets, to make profits from them and to dispose of them at its discretion.”