Crypto held on foreign exchanges — what should I check first?

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Answer

Reporting turns on where the platform or custodian is and on how the holding is characterised, and it can apply even where nothing was sold. One question decides whether this is a filing or a project.

What to check first

Reporting turns on where the platform or custodian is and on how the holding is characterised, and it can apply even where nothing was sold. Self-custody is treated differently from custodial holdings in several systems.

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Where the general answer is wrong

Crypto held on an exchange outside your country is, in most reporting regimes, foreign property held with a foreign institution — regardless of whether the asset itself has a location.

Where to go from here

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on Crypto held on foreign exchanges. If you already have an adviser, we will tell you what they should be asking rather than replacing them.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

Files that look like this one

Case study 1

Establishing which entity held the coins on each platform

A client held balances on several platforms and assumed the analysis was the same for all of them. We read the account-opening terms in force for each year and found three different contracting entities in three jurisdictions, one of which had changed mid-period after a corporate reorganisation. Another platform disclosed a named third-party custodian elsewhere again. The engagement produced a schedule of holdings mapped to the entity and jurisdiction that actually held them, the governing terms attached as support, and a written position on the reporting treatment of each.

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Case study 2

A holding never sold that still needed reporting

The client came to us because a bank had asked a question, not because anything had been sold. Coins bought years earlier had sat untouched on a foreign platform through several filing years, and on that basis reporting had never been considered. We established the acquisition dates, the cost of each lot and the balances held at each year end, then set out which years carried an obligation on the holding alone. The engagement produced a completed set of filings for those years and a memorandum recording why a year with no activity was still a reporting year.

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Case study 3

Separating self-custody from custodial balances across one year

A client moved coins between a platform account and a hardware wallet repeatedly, and the tracking software treated the wallet as simply another account. Because custodial and self-custodied holdings can fall under different rules, the mixed presentation made the reporting position impossible to state. We traced each movement to an address and rebuilt the year as two parallel records, one for coins held with a platform and one for coins held under the client's own keys. The engagement produced that split record and a documented basis for the treatment applied to each side.

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Case study 4

Reconstructing balances after a platform withdrew from the market

The platform stopped serving the client's country and the statement history went with it. We rebuilt the account from the chain: deposits and withdrawals matched to the addresses the platform had used, trade confirmations recovered from old email, and currency movements tied to bank entries. Where a gap remained we said so rather than smoothing it over. The engagement produced a reconstructed holding and cost record with the method written up beside it, the working papers retained, and the filings for the affected years prepared on that basis.

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Case study 5

Transfers between the client's own wallets read as sales

Software had scored every outbound movement as a disposal, which turned routine housekeeping into a long list of taxable events and badly overstated the position. We went through the withdrawal history address by address and matched each outbound movement to an inbound one on an account the client controlled. Most resolved as transfers. A handful did not, and were treated as disposals. The engagement produced a corrected transaction record, a mapping of the client's own addresses that can be reused each year, and a note of the movements that remained genuine disposals.

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Case study 6

A layered custody chain that moved the reporting answer

On its face the client dealt with a platform in one country. The terms disclosed that client assets were held by a separate custodian incorporated somewhere else, and a further agreement pointed to a third jurisdiction for part of the balance. Which location governed the reporting question was the whole engagement. We set out the chain of holding from the client's account to the entity with the keys, took a position on the location that mattered, and documented the alternative reading. The client received that analysis in writing with the source documents attached.

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Case study 7

A Foreign Affiliate Return Filed Years Late

The reporting obligation on a company held abroad runs separately from the corporate return and carries its own exposure. The work is reconstructing the surplus position across the open years before any filing goes in.

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Case study 8

Canadian Dividends and Interest Paid to a Non-Resident

Flat withholding applies at source whether or not a return would produce the same figure. The engagement establishes treaty entitlement, files what is needed to claim the reduced rate, and recovers what went out at the domestic rate.

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Asked next about Crypto held on foreign exchanges

Do I have to report crypto if I never sold anything?

In most reporting systems the obligation attaches to holding the property, not to disposing of it. A year in which you bought nothing, sold nothing and simply left a balance sitting on a foreign platform can still be a reporting year. The disposal question and the reporting question are separate: one decides whether there is tax to pay, the other decides whether a form is due. So work out the reporting position for every year you held the account, not only the years in which you traded. A quiet year is the easiest one to miss and the easiest one to prepare, because the balance and its cost are the only facts needed.

Is crypto on a foreign exchange counted as foreign property?

Usually the question is not asked about the coin at all. A token on a public ledger has no obvious location, so reporting regimes look instead at the arrangement you hold: an account with a platform incorporated somewhere, governed by that platform's terms, with the platform holding the keys. Characterised that way, the holding looks like property held with a foreign institution, and the coin's own placelessness stops being relevant. The first document to read is therefore not a wallet screen but the account agreement, which normally names the contracting entity and the law that governs it.

Does a hardware wallet count as held with a foreign institution?

Self-custody is treated differently from custodial holdings in several systems, and the reason is structural rather than technical. With a hardware wallet there is no counterparty holding anything for you: no account, no institution, no terms of service. Rules written around foreign accounts and foreign custodians may not reach it, while rules written around foreign property more broadly may still do so. Two people with identical balances can land in different places purely on who holds the keys. Record which coins sat in self-custody and which sat with a platform, because that split is the fact the analysis turns on and it is hard to reconstruct later.

How do I find out where my crypto exchange is based?

The website footer is not the answer. Platforms commonly operate through several entities, and the one you actually contracted with is named in the terms you accepted when the account opened, often a different company in a different jurisdiction from the brand. Deeper still, some platforms disclose that client assets sit with a named third-party custodian elsewhere again. Keep the terms in force for each year you held the account, together with any notice of a change of contracting entity. Those documents, not the marketing pages, are what support the position you take and what an examiner will ask to see.

Which exchange records do I need before filing?

Ask the platform for a full transaction export, a year-end statement of balances, and the deposit and withdrawal history including the wallet addresses used. The addresses matter, because they are what let a movement between your own accounts be identified as a transfer rather than a sale. Add the account-opening terms and anything the platform says about which entity holds the assets. Download all of it while the account is live. Access to historic statements ends when a platform leaves a market or shuts down, and a position you cannot document is a position you may have to abandon.

My crypto exchange has closed, what about my reporting?

The obligation does not disappear with the platform. What changes is the evidence available to you, so the work becomes reconstruction: chain records of deposits and withdrawals to and from the addresses the platform used, trade confirmations recovered from old email, bank entries for currency movements, and any statement you saved. From those you can usually rebuild balances and cost with a trail behind each figure. Write down the method you used and its limits, and keep the working papers with the filing. A reconstructed figure supported by a documented method is treated very differently from one that simply appears.

Which country do I pay tax to first?

Generally the source country — where the income arises — taxes first, often by withholding before you receive it. Your country of residence then taxes the same income and credits what the source country took. That order is why timing matters: a residence-country return filed before the source-country tax is settled has nothing to credit yet. Getting the sequence right is most of the work. See international tax planning.

Do Canada and the United States share tax information?

Yes, through more than one channel. The treaty has an exchange-of-information article that supports both routine and on-request exchange. Separately, an intergovernmental agreement has Canadian financial institutions identify US-reportable accounts and report them to the CRA, which passes them to the IRS, with the reverse flow for Canadian residents. Most other country pairs use the Common Reporting Standard for the same purpose. See FATCA reporting.

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