Do I have to report XRP held on a foreign platform or in self-custody on foreign-property or foreign-account forms?

The full answer

These forms are about disclosure, not tax on gains. FinCEN said in 2020 that the FBAR rules do not define a foreign account holding virtual currency as reportable, the Form 8938 instructions checked (Rev. November 2021) do not mention crypto, and no CRA statement on where crypto is located was found. The thresholds and penalties are clear. Whether XRP on a foreign exchange or in your own wallet falls inside them is not, and the agencies have left that open. This page gives general information only. The official pages cited here, or a tax professional, are where a decision about your own filing belongs.

What does Canada’s T1135 cover?

Under the Income Tax Act, a Canadian resident must file Form T1135 when the total cost amount of their specified foreign property exceeds $100,000 at any time in the year. Specified foreign property includes “funds or intangible property, or for civil law incorporeal property, situated, deposited or held outside Canada.”[8] The CRA adds that the $100,000 threshold “is based on the cost amount,” not fair market value, and that meeting it at any time in the year means reporting all such property held during the year.[1] Below $250,000 of total cost throughout the year there is a simplified Part A. At $250,000 or more at any time in the year the detailed Part B applies.[1]

The late-filing penalty is $25 a day for up to 100 days, with a minimum of $100 and a maximum of $2,500. Failing to file knowingly or through gross negligence is $500 a month for up to 24 months, up to $12,000. Further penalties apply after 24 months or after a CRA demand to file.[2]

Does XRP count as foreign property for T1135?

No CRA statement answering this was found on September 29, 2026. According to a 2025 Canadian Tax Foundation article, the CRA said in 2022 that the location of cryptocurrency was still under review, and said in 2023 that where an intermediary such as a trading platform holds it, the relationship between the intermediary and the taxpayer may be relevant. The article concludes that the CRA’s position gives taxpayers no guide for deciding case by case, and argues that crypto held with a Canadian custodian should not meet the definition.[3] The article’s text could not be captured for a word-for-word check, so these points are given as the article’s account only.

That leaves three common situations without an official answer: XRP on a platform based outside Canada, XRP on a Canadian-registered platform whose custody sits abroad, and XRP in self-custody. How platform custody works in Canada is on rules Canadian platforms must follow to hold your XRP.

What about the US FBAR?

US persons file an FBAR when the combined value of their foreign financial accounts exceeds $10,000 at any time in the year.[5] In Notice 2020-2, FinCEN said the FBAR rules “do not define a foreign account holding virtual currency as a type of reportable account,” so such an account is not reportable unless “it holds reportable assets besides virtual currency.” The same notice said FinCEN “intends to propose to amend the regulations” to include virtual currency.[4] No final or proposed rule making that change was found as of September 29, 2026. The notice speaks of accounts. It says nothing about wallets the holder controls directly. Form 8938 is filed with the tax return by unmarried taxpayers living in the US whose specified foreign financial assets exceed $50,000 on the last day of the year or $75,000 at any time, and by joint filers living in the US above $100,000 or $150,000. Not filing can bring a $10,000 penalty [6].

Does Form 8938 cover XRP?

Unmarried taxpayers living in the US must file Form 8938 when their specified foreign financial assets exceed $50,000 on the last day of the year or $75,000 at any time. For joint filers living in the US the figures are $100,000 and $150,000.[6] The form is due by the return’s due date, including extensions.[7] Missing that date can bring a $10,000 penalty. Continued failure more than 90 days after an IRS notice can add $10,000 for each 30-day period, up to $50,000 more.[7] The instructions, revised November 2021, contain no mention of digital assets, virtual currency or crypto in the copy checked for this page, and no other IRS statement on crypto and Form 8938 was found.

Where do the positions differ?

No agency has settled the question in either country. Practitioners writing for the Canadian Tax Foundation, by the article’s own account, treat location as a legal question the CRA has not answered, and argue that Canadian custody keeps crypto off T1135.[3] In the US, FinCEN’s notice says foreign crypto-only accounts are outside the FBAR for now, but announces an intent to change that.[4] Anyone relying on either position is relying on the absence of a rule, which can change. The tax on gains is a separate question, covered on do I pay tax on XRP in Canada or the US, and the records that support either filing are on what records to keep for crypto taxes.