Absolutely not. First, the failure to maintain records is a summary-conviction criminal offence under section 238 of the Income Tax Act. Anyone who fails to comply with the above-mentioned record-keeping requirements may face a minimum fine of $1,000 (up to a maximum of $25,000), plus up to 12 months’ imprisonment. Second, Canadian cryptocurrency users who lack proper records will be at the CRA’s mercy during a cryptocurrency tax audit. When a taxpayer’s dismal record-keeping precludes a Canada Revenue Agency tax auditor from using the standard (generally, more reliable) tax-audit techniques, the tax auditor will employ an indirect method of income verification. The problem is that indirect-income-verification methods don’t give accurate results, and, when used by a CRA tax auditor, these methods typically lead to wildly inflated income-tax assessments. The Canada Revenue Agency’s advantage lies in the fact that, under Canada’s income-tax system, the taxpayer has the initial onus of rebutting the CRA’s assumptions. So, your lack of cryptocurrency-transaction records will ultimately benefit the Canada Revenue Agency.