FROM: Rotfleisch & Samulovitch Professional Corporation

TO: Mr. Jaspinder Sidhu

DATE: January 10, 2022
RE: Crypto-Currency Transactions – Understanding of Facts

REQUIREMENTS
Please prepare a memorandum examining the following issues:
 The income-tax characterization of Mr. Jaspinder Sidhu’s proceeds from transactions
involving cryptocurrency – that is, whether the gains (or losses) from these transactions
should be reported as (i) capital gains (or losses) or (ii) business income (or a business
loss) (for your information, we have taken the position in the past that some transactions
are on capital account and some transactions are on income account);
 The best means of addressing any compliance issues under the Income Tax Act in relation
to Mr. Jaspinder Sidhu’s cryptocurrency transactions and holdings;
 The appropriate scope and filing position of a voluntary-disclosure application (if your
research shows that such an application is indeed the best means of remedying his past
non-compliance); and
 Any other recommendation that you determine warrants Mr. Jaspinder Sidhu’s attention.

Please prepare a detailed and substantive analysis of the relevant law, including the Income Tax
Act and case law. Cite all authorities.

The Understanding of Facts section contain all salient facts for your research. If the
Understanding of Facts section does not speak to a fact that you believe is relevant, please (1)
identify the relevant yet missing fact and (2) explain how the missing fact bears on the analysis
3) contact us forthwith for clarification.

UNDERSTANDING OF FACTS  
Crypto-Currency Transactions: Facts and Assumptions of Fact Requiring Confirmation or
Elaboration  
 
Please carefully review the factual statements below. If any statements are incorrect, please
identify the error and correct the statement.  
 
We also ask that you provide certain details. These enquiries are in bold. Please be specific with
your responses. If you are unsure about how to answer a question, please answer as you see
fit, and we will advise you if we require additional information. 
 
This questionnaire is in Word format for ease of editing. Please write your responses and
corrections directly into this document (preferably, in a different font, typeface, or colour so that
we may easily recognize your edits).   
 
Once you have completed this questionnaire, please return the completed version to the sender.  
 
This document contains seven sections: 
 
1. Background
2. Jaspinder’s Employment History
3. Jaspinder Enters the Crypto-Currency Market: Jaspinder’s 2017 Crypto-Currency
Transactions
4. Jaspinder’s 2018 Cryptocurrency Transactions
5. Jaspinder’s 2019 Crypto-Currency Transactions
6. Jaspinder’s 2020 Crypto-Currency Transactions
7. Other Relevant Details
Background

Mr. Jaspinder Sidhu was born on August 9, 1968.

Jaspinder currently resides at 1126 Montgomery Drive, Oakville, Ontario, L6M 1G1.

From 1987 to 1990, Jaspinder attended McMaster University for his Bachelor of Science in
Biology.

From 1990 to 1994, Jaspinder attended the Canadian Memorial Chiropractic College for his
Doctor of Chiropractic.

Jaspinder has never received any formal education or training in securities trading, finance, or
commerce.

Jaspinder’s Employment History

This section outlines Jaspinder’s employment history since graduating as a Chiropractor in 1994:

From 1994 to 1999, Jaspinder worked full-time as a Clinical Director with the Metro
Orthopedic Rehabilitation Clinics. This role consisted of Jaspinder working as a Chiropractor,
in addition to creating new programs (Osteoporosis, Orthopedic, cardio) and collaborating with
specialists to implement these programs.

From May 2000 to November 2003, Jaspinder worked full-time as a Chiropractor and a
Clinical Director with the ACT Health Group.

From November 2003 to August 2005, Jaspinder worked full-time as President of the
Downtown Injury Rehab Centre. This role consisted of Jaspinder working as a Chiropractor,
in addition to helping create a new weight loss system for the clinic.

From August 2005 to November 2011, Jaspinder worked as Vice President, Clinical Services
with WAVE Manufacturing. This role consisted of Jaspinder working part-time as a
Chiropractor and working part-time creating training and rehabilitation programs for a
new vibration exercise technology.
  
From November 2012 to December 2017, Jaspinder worked full-time as a Chiropractor with
Core Health Care.

On August 28, 2013, Jaspinder incorporated Wizard of Health Inc. (Wizard), pursuant to the
Business Corporations Act (Ontario). Through Wizard Jaspinder achieved the following: (i)
founded the Wizard of Health brand; (ii) developed and launched several health related products,
from initial design, manufacturing and integrating with online e-commerce sales channels,
including Amazon; (iii) developed an e-commerce platform with focus on Search Engine
Optimization (SEO), content marketing and landing page optimization; (iv) helped launch,
develop sales copy, and implement paid traffic strategies on the Amazon.com marketplace; and
(v) developed content for, and optimized, educational videos for a Youtube channel with over a
million views and growing. As of January 10. 2021, Wizard is an active corporation.

From October 2018 to January 2019, Jaspinder worked full-time as a Consultant for Imagination
Capital Corp. Imagination Capital Corp. is the parent company of Shopivo Inc., an e-commerce
planform.

On November 15, 2018, Imagination Capital incorporated Shopivo Inc., pursuant to the Business
Corporations Act (Ontario). In addition, on November 15, 2018, Jaspinder was appointed as
Director and President of Shopivo Inc.

On February 2, 2019, Jaspinder began working full-time for Shopivo Inc., earning $70,000 per
annum. Since February 2, 2019, 100% of Jaspinder’s employment income is earned from
Shopivo Inc.

On April 16, 2021, Shopivo Inc. issued 1,300,000 Common Shares without par value to
Jaspinder. Jasper paid $1.00 to Shopivo Inc. as payment for the 1,300,000 Common Shares.

Jaspinder Enters the Crypto-currency Market: Jaspinder’s 2017 Cryptocurrency

Transactions

Jaspinder first entered the cryptocurrency market in 2017.

By December 31, 2017, Jaspinder’s cryptocurrency portfolio included 4 different cryptocurrency

types. The following sections examine Jaspinder’s transactions involving the following
cryptocurrencies: AE, EOS, XTZ and CVC.

AE Transactions

On May 25, 2017, Jaspinder first entered the cryptocurrency market with a purchase of
10,711.57884 units of Aeternity (“AE”) for $4,334.65.1 (Unless expressly noted otherwise, any
reference to fiat currency is expressed in Canadian-dollar equivalent). The 10,711.57884 units of
AE were purchased on behalf of Jaspinder by a colleague, who held the units on Jaspinder’s
behalf until December 29, 2020. The reason why the units were held by the colleague until
December 29, 2020, was because Jasper simply did not need the units before this time. Jaspinder
gave his colleague $4,334.65 in cash to purchase the 10,711.57884 units of AE. 2 There is no
written agreement reflecting the arrangement between Jaspinder and his colleague as it was made
verbally, in person.

EOS Transactions
1
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
2
When asked about how this cryptocurrency purchase was conducted, Jaspinder indicated “Since I had no technical
knowledge, I believe all purchases were made during the ICO. I believe all ICOs were conducted on ICO project
website with tokens transferred to my friend.”
On June 25, 2017, Jaspinder acquired 2,605.927 units of EOS.IO (“EOS”) for $3,457.02.3 The
2,605.927 units of EOS were purchased on behalf of Jaspinder by a colleague, who held the units
on Jaspinder’s behalf until June 29, 2018. The reason why the units were held by the colleague
until June 29, 2018, was because Jasper simply did not need the units before this time. Jaspinder
withdrew $3,457.02 from his personal account with Royal Bank and gave the $3,457.02 to his
colleague to purchase the 2,605.927 units of EOS for Jaspinder.4 There is no written agreement
reflecting the arrangement between Jaspinder and his colleague as it was made verbally, in
person.

XTZ Transactions (Jaspinder Sidhu)

On July 1, 2017, Jaspinder acquired 9,000.00 units of Tezos (“XTZ”) for $5,371.68.5 To
purchase the 9,000.00 units of XTZ units, Jaspinder withdrew $5,371.68 from his personal
account with Royal Bank and sent these funds to his friend to make the purchase on his behalf.
Although the 9000 units of XTZ were purchased by Jaspinder on July 1, 2017, when the
purchase was initially made, the units were only released to token holders in 2018.6

XTZ Transactions (Mr. Tejinder Chhina)

On July 1, 2017, Jaspinder received from his cousin, Mr. Tejinder Chhina, $1,790.56 in cash
with instructions to purchase units of Tezos (“XTZ”) for the $1,790.56. On July 1, 2017,
Jaspinder purchased 3000 units of XTZ for $1,790.56 on behalf of Mr. Chhina. Jaspinder held
entitlement to the tokens as of July 1, 2017, when the purchase was initially made, but the 3000
units were only released to token holders in 2018. As of January 10, 2022, Jaspinder is still
holding the 3,000 units of XTZ, including any staking rewards acquired under the initial
purchase of the units of XTZ, for the sole benefit of Mr. Chhina.

CVC Transactions (Jaspinder and Mr. Tejinder Chhina))

On July 17, 2017, Jaspinder acquired 63,205 units of Civic (CVC) for $8,209.10. 7 The 63,205
units of CVC were purchased on Jaspinder’s behalf by a colleague, who then transferred the
units to Jaspinder on July 17, 2017. There is no written agreement reflecting the arrangement

3
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
4
When asked about how this cryptocurrency purchase was conducted, Jaspinder indicated “Since I had no technical
knowledge, I believe all purchases were made during the ICO. I believe all ICOs were conducted on ICO project
website with tokens transferred to my friend.”
5
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
6
When asked about how this cryptocurrency purchase was conducted, Jaspinder indicated “Since I had no technical
knowledge, I believe all purchases were made during the ICO. I believe all ICOs were conducted on ICO project
website with tokens transferred to my friend.”
7
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
between Jaspinder and his colleague as it was made verbally, in person. Jaspinder bought Bitcoin
from QuadrigaCX8, transferred the Bitcoin to Bittrex to acquire the 63,205 units of CVC.9

However, Jaspinder does not have sole beneficial interest in all of the 63,205 CVC units.
Half of the CVC units, namely 31,607.5 units of CVC, were purchased for Jaspinder while
the other half were acquired on Mr. Tejinder Chhina’s behalf. On July 1, 2017, Jaspinder
received from his cousin, Mr. Tejinder Chhina, $4,104.55 in cash and instructions to
acquire CVC, for Mr. Chhina’s behalf, using the $4,104.55. Subsequently, Jaspinder gave
the $4,104.55, that he initially received from Mr. Chhina, to a colleague of Jaspinder in
order for the colleague to purchase the units of CVC on behalf of Mr. Chhina. As of
September 27, 2021, Jaspinder is still holding the 31,607.50 units of CVC, including any
staking rewards acquired under the initial purchase of the units of CVC, for the sole benefit
of Mr. Chhina.

Jaspinder did not borrow money to purchase any of the cryptocurrency that he acquired in 2017.
To fund his cryptocurrency purchases in 2017, Jaspinder used funds from his personal
savings, which stemmed from his employment income.

As of December 31, 2017, Jaspinder owned 10,711.57884 units of AE, 2,605.927 units of
EOS, 9,000 units of XTZ (6,000 units for Jaspinder and 3,000 units for Mr. Tejinder
Chhina), and 63,215 units of CVC (31,607.50 units for Jaspinder and 31,607.50 units for
Tejinder Chhina).

After acquiring AE, EOS, XTZ and CVC in 2017, Jaspinder neither purchased nor sold any
cryptocurrency until 2019.

Jaspinder’s Tax Residence for all years

Jaspinder is a Canadian citiz en and has remained as a Canadian resident for tax purposes for all
of the relevant tax years.

Jaspinder’s 2017 Income-Tax Return

For the 2017 tax year, Jaspinder reported taxable income of $12,927.05, which consisted of
Jaspinder’s net business and professional income (minus a $490.94 deduction for CPP
contributions).

Jaspinder did not report any gains or losses relating to cryptocurrency transactions on his 2017
income-tax return.

The peak cost of Jaspinder’s crypto-currency portfolio during the period from January 1, 2017,
to December 31, 2017 was $23,163.01. Therefore, the total cost of Jaspinder’s cryptocurrency

8
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
9
When asked about how this cryptocurrency purchase was conducted, Jaspinder indicated “Since I had no technical
knowledge, I believe all purchases were made during the ICO. I believe all ICOs were conducted on ICO project
website with tokens transferred to my friend.”
portfolio never exceeded $100,000 at any time during the period from January 1, 2017, to
December 31, 2017. Jaspinder’s 2017 income-tax return did not include a T1135 form.

Jaspinder’s 2018 Cryptocurrency Transactions

In 2018, Jaspinder acquired Bitcoin from QuadrigaCX in order to purchase units of CVC and
MIOTA. The exact date of the purchase of Bitcoin is not known because QuadrigaCX ceased
operations in 2019 and Jaspinder no longer has access to his QuadrigaCX account which was
used to purchase Bitcoin. However, Jaspinder has records of his e-transfer payments which were
made from his TD bank account to his QuadrigaCX account to fund his Bitcoin purchases:

 On November 26, 2018, Jaspinder e-transferred $1,031.90 CAD from his TD bank
account to his QuadrigaCX account to fund his Bitcoin purchases;
 On November 28, 2018, Jaspinder e-transferred $515.95 CAD from his TD bank account
to his QuadrigaCX account to fund his Bitcoin purchases;
 On December 3, 2018, Jaspinder e-transferred $515.95 CAD from his TD bank account
to his QuadrigaCX account to fund his Bitcoin purchases;
 On December 13, 2018, Jaspinder e-transferred $1,547.85 CAD from his TD bank
account to his QuadrigaCX account to fund his Bitcoin purchases;
 On December 18, 2018, Jaspinder e-transferred $1547.85 CAD from his TD bank
account to his QuadrigaCX account to fund his Bitcoin purchases;

In 2018, the following transactions were carried out by Jaspinder all of which involved the
acquisition of a total of 35,398.76311 units of Civic (CVC) and the disposition of a total of
0.54144053 Bitcoin:

 On November 28, 2018, Jaspinder purchased 5591.619718 units of CVC. To purchase the
5591.619718 units of CVC, Jaspinder bought 0.08755940 Bitcoin from QuadrigaCX10,
transferred the 0.08755940 Bitcoin to Bittrex, then he used the Bitcoin to purchase the
5591.619718 units of CVC. 11
 On November 29, 2018, Jaspinder purchased 5176.944104 units of CVC. To purchase the
5176.944104 units of CVC, Jaspinder bought 0.08127353 Bitcoin from QuadrigaCX12,
transferred the 0.08127353 Bitcoin to Bittrex, then he used the Bitcoin to purchase the
5176.944104 units of CVC.13
 On December 7, 2018, Jaspinder purchased 6469.376628 units of CVC. To purchase the
6469.376628 units of CVC, Jaspinder bought 0.09663478 Bitcoin from QuadrigaCX14,
transferred the 0.09663478 Bitcoin to Bittrex, then he used the Bitcoin to purchase the
6469.376628 units of CVC. 15

10
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
11
Jaspinder sold these 5591.619718 units of CVC in 2021.
12
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
13
Jaspinder sold these 5176.944104 units of CVC in 2021.
14
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
15
Jaspinder sold these 6469.376628 units of CVC in 2021.
  On December 18, 2018, Jaspinder bought 0.27597222 Bitcoin from QuadrigaCX16,
transferred the 0.27597222 Bitcoin to Bittrex. On December 19, 2018, Jaspinder used the
0.27597222 Bitcoin to purchase 18160.82266 units of CVC.

In 2018, the following transactions were carried out by Jaspinder all of which involved the
acquisition of a total of 3,199 units of MIOTA and the disposition of a total of 0.24657892
Bitcoin:

 On December 19, 2018, Jaspinder purchased 3,199 units of MIOTA. To purchase

the 3,199 units of MIOTA, Jaspinder used QuadrigaCX17 exchange to buy 0.24657892
Bitcoin, then transferred the 0.24657892 Bitcoin to Binance, and used the 0.24657892
Bitcoin to purchase the 3,199 units of MIOTA.

For 2018, Jaspinder made no other acquisitions or dispositions of cryptocurrencies.

Jaspinder did not borrow money to purchase any of the cryptocurrency that he acquired in 2018.

As of December 31, 2018, Jaspinder owned 10,711.57884 units of AE, 2,605.927 units of
EOS, 9000 units of XTZ (6,000 units for Jaspinder and 3,000 units for Mr. Tejinder
Chhina), 98,613.76 units of CVC (67,006.26 units for Jaspinder and 31,607.50 units for
Tejinder Chhina), and 3,199 units of MIOTA.

Jaspinder’s 2018 Income-Tax Return

For the 2019 tax year, Jaspinder reported taxable income of $22,819.81, which consisted of
Jaspinder’s employment income and net business and income (minus an $1,006.14 deduction for
CPP contributions).

The peak cost of Jaspinder’s crypto-currency portfolio during the period from January 1, 2018, to
December 31, 2018 was $27,290.61. Therefore, the total cost of Jaspinder’s cryptocurrency
portfolio never exceeded $100,000 at any time during the period from January 1, 2018, to
December 31, 2018. Jaspinder’s 2018 income-tax return did not include a T1135 form.

Jaspinder’s 2019 Cryptocurrency Transactions

In 2019, Jaspinder acquired Bitcoin (“BTC”) as part of his cryptocurrency holdings.

In 2019, a total of 12 transactions were carried out by Jaspinder involving 2.06084455 units
BTC, all of which were acquisitions:

16
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
17
In 2019, QuadrigaCX ceased operations and the company was declared bankrupt.
  On April 30, 2019, Jaspinder made two purchases of 0.42951624 units of BTC for
$3,100.0018 ($7,217.42 per unit) over coinsquare.com, an online marketplace for purchase
and sale of cryptocurrencies.
 From May 13, 2019, to December 17, 2019, Jaspinder purchased an additional
1.63132831 BTC units for a total cost of $18,357.50 19 ($11,253.10 per unit) over
coinsquare.com.

Jaspinder did not acquire any cryptocurrency other than BTC in 2019, and he did not dispose of
any cryptocurrency in 2019.

Jaspinder did not borrow money to purchase any of the BTC that he acquired in 2019. To acquire
BTC in 2019, Jaspinder used either the funds from his personal TD Canada Trust savings or the
proceeds from prior cryptocurrency dispositions.

As of December 31, 2019, Jaspinder owned 10,711.57884 units of AE, 2,605.927 units of
EOS, 9000 units of XTZ (6,000 units for Jaspinder and 3,000 units for Mr. Tejinder
Chhina), 98,613.76 units of CVC (67,006.26 units for Jaspinder and 31,607.50 units for
Tejinder Chhina), 3,199 units of MIOTA, and 2.06084455 units of BTC.

Jaspinder’s 2019 Income-Tax Return

For the 2019 tax year, Jaspinder reported taxable income of $79,659.81, which consisted of
Jaspinder’s employment income and net business and income (minus an $80.05 deduction for
CPP contributions).

The peak cost of Jaspinder’s crypto-currency portfolio during the period from January 1,
2019, to December 31, 2019 was $48,748.11. Therefore, the total cost of Jaspinder’s
cryptocurrency portfolio never exceeded $100,000 at any time during the period from
January 1, 2019, to December 31, 2019. Jaspinder’s 2019 income-tax return did not include a
T1135 form.

Jaspinder did not dispose of any cryptocurrency in 2019. Therefore, there was no gain or loss for
to report on his 2019 Income Tax Returns.

Jaspinder’s 2020 Cryptocurrency Transactions

In 2020, Jaspinder’s cryptocurrency portfolio included, at one time or another, of 16 different

cryptocurrency types.

In 2020, Jaspinder executed a total of 740 crypto-currency transactions consisting of: 465
acquisitions and 275 dispositions.
18
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
19
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
Jaspinder’s total profits from cryptocurrency transactions in 2020 was $57,717.83. Jaspinder’s
dispositions of XTZ, BTC, and Etherium (“ETH”) were responsible for about 91% of his
2020 profits. About 63% of Jaspinder’s profits came from Jaspinder’s sale of XTZ. Jaspinder’s
profit from selling XTZ was $36,241.82.

The total of Jaspinder’s cryptocurrency profits for 2020 stemmed from:

 $36,241.82 in gains from converting XTZ to Tether (“USDT”);

 $7,265.47 in gains from converting BTC to Kusama (“KSM”);
 $8,962.02 in gains from converting ETH to USDT;
 $1,917.00 in losses from conversion of ETH to BTC and then USDT;
 $4,287.90 in gains from converting EOS to USD Coin (“USDC”);
 $1,108.65 in gains from converting BTC to USDC to LTO Network (“LTO”);
 $1,667.90 in gains from converting USDT to KSM;
 $0.01 in gains from purchasing Chainlink (“LINK”) with USDC;
 $839.34 in gains from purchasing Etherium Vault (“ETHV”) with USDC and ETH;
 $3,170.15 in losses from conversion of AE to USDC;
 $3.13 in losses from purchase of API3 with USDC;
 $1,826.57 in gains from staking XTZ proceeds from sale;
 $542.33 in gains from staking LTO proceeds from sale;
 $71.88 in gains from conversion of USDT to USDC;
 $5.85 in losses from conversion of USDC to USDT;
 $0.07 in gains from conversion of USDC to ETH.

The following sections examine Jaspinder’s transactions involving the following

cryptocurrencies: AE, XTZ, LTO, BTC, EOS, ETH, ETHV, USDT, USDC and UNI.

AE Transactions

On December 30, 2020, Jaspinder converted 10,711.57 AE units for 914.77 units of USDT with
a total value of $1,173.1420 (a value of $1.28 per unit). Jaspinder’s disposition of the 10,711.57
AE units resulted in an overall loss of $3,170.15.

XTZ Transactions

Starting in 2020, Jaspinder began “staking” his XTZ holdings. Cryptocurrencies such as XTZ
operate using a “proof-of-stake” consensus mechanism for validating transactions, rather than a
“proof-of-work” model like that of BTC. Proof-of-work models rely on heavy computing power
to solve mathematical problems in order to validate new blocks on a blockchain. A proof-of-
stake model relies on cryptocurrency owners “staking” cryptocurrency by locking a quantity of
cryptocurrency in a wallet in order to become a node. A random node is selected periodically to

20
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
act as the validator for the next block on the blockchain. A node chosen to validate the next
block will receive the transaction fees associated with the transactions in that particular block. In
a practical sense, it operates as a means of passively generating income equivalent to interest on
cryptocurrency.

From January 30, 2020, to December 31, 2020, Jaspinder received 118 payments of XTZ as a
result of his XTZ staking arrangements. Specifically, he received a total of 521.725684 XTZ
units21 with an aggregate value of $1,826.57 (a value of $3.50 per unit).

On August 25, 2020, Jaspinder converted 9,100 units from the XTZ across 35 transactions for
32,269.97867 USDT units worth a total of $42,022.15. Jaspinder’s disposition of the 9,100.00
XTZ units resulted in an overall gain of $36,241.84.

LTO Transactions

On June 12, 2020, Jaspinder staked 124,876.988 LTO units. From June 19, 2020, to December
30, 2020, Jaspinder’s LTO stakes were responsible for 50 transactions. From Jaspinder’s LTO
stakes, he received a total of 4,552.49 LTO units 22 with an average total value of $542.33 (a
value of $0.12 per unit).

BTC Conversion Transactions

For 2020, Jaspinder engaged in a total of 56 transactions involving BTC:

 On March 14, 2020, Jaspinder converted 0.245773 BTC units across 4 transactions for
1,335.984387 USDT units valued at a total of $1,729.39. 23 Jaspinder’s disposition of the
0.245773 BTC units resulted in an overall loss of $1,005.24.
 On June 8, 2020, he converted 0.10251958 BTC units for a total of 18,113.00 LTO units
valued at $1,348.46.24 Jaspinder’s disposition of the 0.10251958 BTC units resulted in an
overall gain of $198.31.
 On June 9, 2020, he converted 0.62749713 BTC units across 3 transactions for a total of
106,899.00 LTO units valued at $8,326.54.25 Jaspinder’s disposition of the 0.62749713
BTC units resulted in an overall gain of $925.11.

21
The amounts and values of XTZ received by Jaspinder when receiving XTZ units from his staking activities
include any transaction fees levied against Jaspinder for the transfer to his cryptocurrency wallet.
22
The amounts and values of LTO received by Jaspinder when receiving LTO units from his staking activities
include any transaction fees levied against Jaspinder for the transfer to his cryptocurrency wallet.
23
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
24
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
25
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
  On August 25, 2020, he converted 2.04003231 BTC units across 48 transactions for a
total of 680.0587 KSM units valued at $31,035.35.26 Jaspinder’s disposition of the
2.04003231 BTC units resulted in an overall gain of $7,265.47.

EOS Transactions

On March 31, 2020, Jaspinder converted 2,605.92 EOS units across 6 transactions for
5,802.602064 USDC units valued at a total of $7,783.84. 27 Jaspinder’s disposition of the
2,605.92 EOS units resulted in an overall gain of $4,287.90.

ETH Transactions

For 2020, Jaspinder engaged in a total of 33 transactions involving ETH:

 On March 14, 2020, Jaspinder converted 10.26 ETH units across 2 transactions for
0.24597324 BTC units valued at a total of $1,714.44.28 Jaspinder’s disposition of the
10.26 ETH units resulted in an overall loss of $911.76.
 On August 25, 2020, Jaspinder converted 37.993541 ETH units across 29 transactions for
14,947.21951 UDST units valued at a total of $19,541.31. 29 Jaspinder’s disposition of the
37.993541 ETH units resulted in an overall gain of $8,962.02.
 On August 27, 2020, Jaspinder purchased 0.00263247 ETH units worth a total of $1.35.

ETHV Transactions

On August 19, 2020, Jaspinder converted a total of 2.91924432 ETH units and 200 USDC units
across 3 transactions for 1,464.213316 ETHV units valued at a total of $1,999.75. 30 Jaspinder’s
disposition of the 2.91924432 ETH units and 200 USDC units resulted in an overall gain of
$839.34.

USDT Transactions

For 2020, Jaspinder engaged in a total of 119 transactions involving USDT:

26
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
27
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
28
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
29
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
30
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
  On March 28, 2020, Jaspinder converted 1,334.639538 USDT units across 2 transactions
for 1,337.18 USDC units valued at a total of $1,799.51.31 Jaspinder’s disposition of the
1,334.639538 USDT units resulted in an overall gain of $71.88.
 On August 17, 2020, Jaspinder converted 6,018.334125 USDT units across 19
transactions for 444.1575 KSM units valued at a total of $8,044.28.32 Jaspinder’s
disposition of the 6,018.334125 USDT units resulted in an overall gain of $46.67.
 On August 18, 2020, Jaspinder purchased 1502.34 USDT units across 2 transactions for a
total of $2,017.08 via INTERAC transfer through Paytrie.com.
 On August 18, 2020, Jaspinder converted 1500.838514 USDT units across 6 transactions
for 110.5183 KSM units valued at a total of $2,015.07. 33 Jaspinder’s disposition of the
1500.838514 USDT units resulted in an overall loss of $0.01.
 On August 22, 2020, Jaspinder converted 2,995.2965 USDT units across 11 transactions
for 171.1598 KSM units valued at a total of $4,032.31. 34 Jaspinder’s disposition of the
2,995.2965 USDT units resulted in an overall gain of $13.76.
 On August 25, 2020, Jaspinder converted 14,911.93921 UDST units across 15
transactions for 465.7056 KSM units valued at a total of $19,982.30.35 Jaspinder’s
disposition of the 14,911.93921 UDST units resulted in an overall gain of $486.68.
 On August 25, 2020, Jaspinder converted 32,116.9706 USDT units across 63 transactions
for 856.2212 KSM valued at a total of $43,037.31.36 Jaspinder’s disposition of the
32,116.9706 USDT units resulted in an overall gain of $1,214.14.
 On September 22, 2020, Jaspinder purchased 1,496.04 USDT units for a total cost of
$2,012.49.
 On August 27, 2020, Jaspinder purchased 1,507.52 USDT units for a total of $2,023.68.

USDC Transactions

For 2020, Jaspinder engaged in a total of 28 transactions involving USDC:

 On June 8, 2020, Jaspinder converted 999.999561 USDC units for 0.102623 BTC units
valued at a total of $1,341.06.37 Jaspinder’s disposition of the 999.999561 USDC units
resulted in an overall loss of $1.19.

31
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
32
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
33
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
34
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
35
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
36
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
37
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
  On June 9, 2020, Jaspinder converted 6,127.432625 USDC units across 4 transactions for
0.628125 BTC units valued at a total of $8,210.96.38 Jaspinder’s disposition of the
6,127.432625 USDC units resulted in an overall loss of $13.58.
 On June 12, 2020, Jaspinder purchased a total of 725.53 USDC units across 2
transactions for a total cost of $974.24.
 On June 12, 2020, Jaspinder converted 728.583219 USDC units across 2 transactions for
178.43 LINK units worth a total of $978.34.39 Jaspinder’s disposition of the 728.583219
USDC units resulted in an overall gain of $0.01.
 From August 9 to August 17, Jaspinder purchased an additional 6,044.85 USDC units
across 5 transactions for a total of $8,107.09.
 On August 17, 2020, Jaspinder converted 6,038.811189 USDC units across 8 transactions
for 6,024.352742 USDT units valued at a total of $8,099.08. 40 Jaspinder’s disposition of
the 6,038.811189 USDC resulted in an overall gain of $0.08.
 On August 19, 2020, Jaspinder purchased 1,503.34 UDSC units for a total of $2,024.86.
 On August 19, 2020, Jaspinder converted 1,301.84153 USDC units for 3.21784 ETH
units valued at a total of $1,753.46.41 Jaspinder’s disposition of the 1,301.84153 USDC
units resulted in an overall gain of $0.07.
 On August 20, 2020, Jaspinder purchased 1,501.37 USDC units for a total of $2,013.55.
 On August 21, 2020, Jaspinder purchased 1,500.52 USDC units for a total of $2,018.90.
 On August 22, 2020, Jaspinder converted 2,298.89111 USDC units for 2,998.29145
USDT units worth a total of $4,022.55.42 Jaspinder’s disposition of the 2,298.89111
USDC units resulted in an overall loss of $5.93.
 On December 30, 2020, Jaspinder converted 10,711.57 AE units for 914.77 USDT units.
Then, on December 31, 2020, Jaspinder converted 912.96 USDT units for 495.5542 units
of API3. This disposition resulted in an overall loss of $2.43.
Additional Cryptocurrency Transactions

In 2020, Jaspinder acquired the following additional cryptocurrency units:

As patronage for using the Uniswap cryptocurrency exchange, on September 18, 2020,
Jaspinder received 400.00 Uniswap (“UNI”) units. The closing value of UNI on
September 18, 2020, was $7.63 per unit. Jaspinder therefore acquired the air-dropped
UNI units with a cost base of $4,029.56. An air-drop is a marketing method employed
generally by startups in the cryptocurrency space that involves sending coins or tokens to
38
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
39
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
40
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
41
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
42
This figure represents the total fair market value, calculated in Canadian currency, of all property (including fiat
currency and cryptocurrency) for which Jaspinder acquired these units.
 wallet addresses in order to promote awareness of a new virtual cryptocurrency.
Generally speaking, an airdrop involves small amounts of new virtual currency being
sent to wallets of active members of the relevant blockchain community for free or in
return for a small service, such as an online promotion of the cryptocurrency. Jaspinder
did not dispose of any units of UNI during 2020.43
As of December 31, 2020, Jaspinder owned 494.5542 units of API3; 400 units of UNI;
1,464.213316 units of ETHV; 129429.478 units of LTO; 98,613.76 units of CVC (67,006.26
units for Jaspinder and 31,607.50 units for Tejinder Chhina); 2726.821144 units of KSM;
177.67157 units of LINK; and 3421.91887 XTZ (421.91887 units for Jaspinder and 3,000 units
for Tejinder Chhina)45.

Jaspinder did not borrow money to fund his 2020 cryptocurrency transactions. Jaspinder’s 2020
cryptocurrency transactions were funded either (i) through his personal RBC and TD savings
accounts whereby Jaspinder converted his personal savings to USDT or USDC through Paytrie
interac transfers, or (ii) through USDT / USDC acquired from prior cryptocurrency dispositions.

Jaspinder’s 2020 Income-Tax Return

For the 2020 tax year, Jaspinder reported taxable income of $144,622.35, which consisted of
$77,300.12 in T4 employment income and $67,487.83 in business income, reduced by
$165.60 in CPP deductions.

Jaspinder’s 2020 income-tax return did not report any income relating to cryptocurrency
transactions.

Jaspinder’s 2020 income-tax return did not include a T1135 form. The peak cost of Jaspinder’s
crypto-currency portfolio during the period from January 1, 2020, to December 31, 2020
was $140,014.10. Therefore, the total cost of Jaspinder’s cryptocurrency portfolio exceeded
$100,000 at a point in time during the period from January 1, 2019, to December 31, 2019.

Other Relevant Details

43
In 2020, Jaspinder also acquired two additional cryptocurrency units. First, on April 27, 2020, Jaspinder obtained
a total of 888888.00 KickToken (“KICK”) units for a total of $6.60. Jaspinder did not dispose of any KICK units
during 2020. Second, on October 25, 2020, Jaspinder received a total of 3.00 PiggyCoin (“PIGI”) units for a total of
$0.00. Jaspinder did not dispose of any PIGI units during 2020. KickToken and PiggyCoin were randomly
airdropped to Jaspinder. Jaspinder expressed that he does not foresee himself ever trading these units.
44
Transactions involving Jaspinder acquiring KSM total 2727.8211 units of KSM. However, the transaction history
shows that 1 KSM was “send” without providing additional information regarding the same. As such, Jaspinder total
amounts of KSM units at the end of 2020 is reduced to 2726.8211 units of KSM.
45
As previously explained, client purchased 9000 units of XTZ in 2017, but the tokens were not released until 2018.
In 2020, Jaspinder started staking the 9000 tokens. Between January 1, 2020 and December 31, 2020, Jaspinder
received 521.91887 units of XTZ as a result of his XTZ staking transactions. However, on August 25, 2021,
Jaspinder converted 9,100 units from the XTZ into USDT and used the USDT acquired to purchase KSM. As such,
as of December 31, 2020, Jaspinder owned 3421.91887 units of XTZ.
Jaspinder spends no more than an hour per week researching cryptocurrency or cryptocurrency-
related technology. And he spends no more than an hour per week engaging in cryptocurrency
transactions.

For research, Jaspinder uses on publicly available materials—specifically, online news releases,
blog and forum posts, and websites for cryptocurrency exchanges. But Jaspinder also receives
information that is not available to the general public. For example, since 2016, Jaspinder has
received general information about cryptocurrencies from developers and executives involved in
cryptocurrency-related software companies. This information typically concerns the future
potential and the development of the cryptocurrency-related technology itself, as opposed to any
specific type of cryptocurrency. In addition, Jaspinder has discussions every few months with
people in the cryptocurrency industry, specifically cryptocurrency-platform developers and
executives. The purpose of these conversations, which may last 1 to 2 hours over lunch or
dinner, is to discuss potential of cryptocurrencies and how people can participate in these
projects by investing, staking or helping to secure the networks.

To date, Jaspinder has never received a notice from the CRA about potential non-compliance
involving the 2017, 2018, 2019, or 2020 tax years. Nor has Jaspinder received any notice
suggesting that the CRA or any other authority may be considering or in the process of an audit,
examination, or investigation of his cryptocurrency transactions or his proceeds therefrom.