Income Tax Statutes for Canadian Bitcoin Miners: Class 50, ACB and the Six-Year Clock

Reference, not tax advice. This page quotes what the Income Tax Act and its Regulations say. It does not describe your situation, compute anything for you, or recommend a filing position. Characterisation questions in tax are decided on facts, and mining operations differ enormously — talk to a Canadian tax professional before acting. Québec administers its own income tax through Revenu Québec.

Quick answer

There is no Bitcoin-mining provision in the Income Tax Act. Mining is taxed through the ordinary machinery, which is why the first question is always whether the activity is a business at all: s. 9(1) makes income from a business the taxpayer's profit from it, and s. 248(1) defines business broadly as "a profession, calling, trade, manufacture or undertaking of any kind whatever". If that gate opens, the rest follows — mining rigs are depreciable property rather than a current expense, falling into Capital Cost Allowance Class 50 at 55% per year for general-purpose data processing equipment, with a modified first-year entitlement; coins carry an adjusted cost base under s. 54 that governs any later disposition; and records must be kept under s. 230 for six years from the end of the last taxation year to which they relate.

Do not expense a miner in the year you buy it — it is Class 50 property at 55% declining balance, with a first-year factor that depends on when it became available for use. Track a per-unit cost for mined coins from day one, because reconstructing it years later is the hard part. Keep your own exported records rather than trusting a pool or exchange dashboard, and count the six years from the end of the tax year, not from the trade.

The rules, with the statute quoted

Each rule below names its provision and quotes the operative language, because in tax the exact words carry the meaning. Every provision here was read directly from the Justice Laws Website while this page was written.

Whether mining is a business at all — the gate for everything else

Income Tax Act s. 9(1) and the s. 248(1) definition of "business"

s. 9(1): "Subject to this Part, a taxpayer's income for a taxation year from a business or property is the taxpayer's profit from that business or property for the year." s. 248(1): "business" "includes a profession, calling, trade, manufacture or undertaking of any kind whatever and, except for the purposes of paragraph 18(2)(c), section 54.2, subsection 95(1) and paragraph 110.6(14)(f), an adventure or concern in the nature of trade but does not include an office or employment".

What it means in practice: There is no crypto-mining provision in the Income Tax Act. Mining is taxed through the ordinary machinery: if the activity is a business, its profit is income under s. 9(1), expenses become deductible against it, and capital cost allowance becomes available. If it is not a business, none of that machinery engages. Every other question on this page — deducting electricity, claiming CCA on rigs, how coins are held — sits downstream of this one.
Common mistake: Treating "hobby" as a status you can elect by keeping the operation small, or assuming that mining at a loss proves it is not a business. Neither follows from the statute. The Act defines business broadly — "an undertaking of any kind whatever" — and characterisation is a question of fact decided on the whole picture, not on machine count.
Where this page stops: This is genuinely fact-dependent and the statute does not resolve it for you. Where an activity has a personal or non-commercial element the analysis is judicial rather than statutory, and a borderline operation needs a Canadian tax professional on the specific facts — not a table. We are stating the statutory frame, not predicting where your facts land.

Mining hardware: Capital Cost Allowance Class 50 at 55%

Income Tax Regulations (C.R.C., c. 945), Schedule II, Class 50; rate at Reg. 1100(1)(a)(xxxvi); first-year factor at Reg. 1100(2)

Schedule II, Class 50: "Property acquired after March 18, 2007 that is general-purpose electronic data processing equipment and systems software for that equipment, including ancillary data processing equipment, but not including property that is included in Class 52 or that is principally or is used principally as (a) electronic process control or monitor equipment; (b) electronic communications control equipment; (c) systems software for equipment referred to in paragraph (a) or (b); or (d) data handling equipment…". Rate: "(xxxvi) of Class 50, 55 per cent".

What it means in practice: Mining rigs are capital equipment, not a current expense. You do not deduct the purchase price in the year you buy it; you add it to a CCA class and deduct a declining-balance percentage each year. For general-purpose computing equipment that class is Class 50 at 55% per year. Note the statutory language is about general-purpose data processing equipment — whether a given machine fits the class is a question of fact about the equipment, not a label you choose.
Common mistake: Expensing the full cost of a miner in the year of purchase. That is not how depreciable property works, and it is one of the most common errors in small mining operations. A second error is assuming the 55% applies in full in year one — the first-year entitlement is modified, see the next row.
Where this page stops: Class membership is a factual determination about the equipment. CCA is also only available against a source of income from a business or property, so it depends entirely on the first row on this page resolving in your favour.

The first-year CCA rules — where stale advice is worst

Income Tax Regulations 1100(2), paragraph (c.3) as it applies to Class 50

Reg. 1100(2): "(c.3) if the class is Class 50, (i) 9/11, for property that was acquired and became available for use by the taxpayer after April 15, 2024 and before 2027, and (ii) nil, for property that became available for use by the taxpayer after 2026".

What it means in practice: The accelerated investment incentive changes the first-year deduction rather than the ongoing rate. For Class 50 property that became available for use after April 15, 2024 and before 2027 there is an enhanced first-year factor of 9/11; for property that becomes available for use after 2026 that enhancement drops to nil. "Available for use" is the trigger, not the purchase date or the invoice date.
Common mistake: Reading older articles that describe full immediate expensing for computer equipment as if it were still open, or assuming the enhancement runs off the date you paid rather than the date the machine became available for use. Both produce a wrong first-year number.
Where this page stops: These windows are date-sensitive and were amended more than once. Check the current text of Reg. 1100(2) for the year you are actually filing before relying on any factor quoted anywhere, including here.

Adjusted cost base — what your coins "cost" you

Income Tax Act s. 54, definition of "adjusted cost base"

s. 54: "adjusted cost base to a taxpayer of any property at any time means, except as otherwise provided, (a) where the property is depreciable property of the taxpayer, the capital cost to the taxpayer of the property as of that time, and (b) in any other case, the cost to the taxpayer of the property adjusted, as of that time, in accordance with section 53…".

What it means in practice: When you later dispose of coins, the gain or loss is measured against adjusted cost base, which starts from the cost of the property and is then adjusted under s. 53. For purchased coins the cost is what you paid. For self-mined coins the question of what "cost" means is exactly where miners need advice, because the coins were produced rather than bought — and the answer interacts with whether the mining was a business and whether the coins are inventory or capital property.
Common mistake: Not tracking a per-unit cost at all until a sale forces the question years later, by which point the records to reconstruct it are gone. A related error is assuming a disposition only happens when you sell for dollars — swapping one crypto-asset for another and paying for goods are also dispositions in ordinary tax terms.
Where this page stops: The cost of self-mined coins and the inventory-versus-capital question are precisely the points where CRA's administrative position matters and where we are deliberately not asserting one. Get professional advice on this specific point.

Records: what you must keep, and for how long

Income Tax Act s. 230(1) and s. 230(4)(b)

s. 230(1): "Every person carrying on business and every person who is required, by or pursuant to this Act, to pay or collect taxes or other amounts shall keep records and books of account (including an annual inventory kept in prescribed manner) at the person's place of business or residence in Canada or at such other place as may be designated by the Minister…". s. 230(4)(b): retain records "until the expiration of six years from the end of the last taxation year to which the records and books of account relate".

What it means in practice: The retention clock is the detail that catches people. It does not run six years from the transaction — it runs six years from the end of the last taxation year to which the records relate. Records must also be kept at a place of business or residence in Canada, or another place the Minister designates, which is a real consideration if your books live only in a foreign exchange account or a hosted dashboard.
Common mistake: Assuming six years from the date of each trade, and assuming an exchange or pool dashboard counts as your records. Platforms close, restrict history, or lose data — and the obligation is yours, not theirs. Export and keep your own copies as you go.
Where this page stops: s. 230(4)(a) refers to records for which a period is prescribed, so specific prescribed periods can differ. If a year is under objection or appeal, retention obligations extend beyond the ordinary six.

What this page deliberately does not tell you

Plenty of the questions miners actually ask are answered by CRA's administrative positions rather than by statute — when exactly mined coins are recognised as income and at what value, whether coins are inventory or capital property, how CRA treats the cost of self-mined coins, and CRA's own view of when mining amounts to a business. We researched all of it. We are not publishing it here.

The reason is specific rather than cautious boilerplate: CRA reorganised its crypto-asset guidance into new subpages in late 2025, canada.ca could not be reached for independent verification while this page was written, and tax content that reads as authoritative while quoting superseded wording causes real financial harm. One concrete example of why that matters — the line quoted all over the web, that mining done "with the intention of profiting in a business-like manner" is a business, appears to be superseded CRA wording that no longer reflects the live guidance. If a page quotes it to you as current, that page has not checked.

So this reference stays where it can stand: on statute. For CRA's administrative positions, go to CRA's own crypto-asset guidance and read the live page, and take the fact-dependent questions to a professional.

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Last reviewed July 20, 2026.