Crypto tax residency rules: What determines your liability in the US, UK, and Canada?

Determining tax residency is essential for anyone earning, transferring, or holding digital assets. Tax obligations on crypto income and gains are driven by domestic residency criteria, which often rely on factors beyond national citizenship or the location of an exchange account. Residency tests differ by country and can consider time spent within a nation, housing situation, employment, and personal connections. Some countries, upon granting residency, assert taxation rights over worldwide income, including digital asset gains. Importantly, the rules for tax residency are separate from those that define whether a particular crypto transaction is taxable. For instance, the US uses multiple standards such as the green-card test and the substantial-presence test for non-citizens.

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