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🇨🇦 T1135 • Specified Foreign Property • $100,000 Threshold • 2026

CRA Form T1135 Foreign Property Reporting Guide 2026

Understand when Form T1135 is required, how the $100,000 cost-amount threshold works, when Part A or Part B applies, how Canadian brokerage accounts are reported, and what penalties can apply for late or inaccurate filing.

1. What Form T1135 is and who must file

Form T1135, Foreign Income Verification Statement, is an information return used to report specified foreign property. It generally applies to Canadian-resident individuals, corporations and certain trusts, and to certain partnerships, when the aggregate cost amount of specified foreign property was more than $100,000 at any time during the tax year. The filing obligation is based on cost amount, not simply year-end fair market value.

Key Framework Highlights:
  • The $100,000 threshold is an aggregate test across specified foreign property.
  • The test is based on cost amount rather than fair market value.
  • The threshold is tested at any time during the year, so falling below $100,000 before year-end does not by itself eliminate the filing obligation.
  • Specified foreign property is a technical statutory category; not every asset located outside Canada is reportable.
  • Form T1135 is an information return and should not be confused with the taxpayer's T1 or corporate income-tax return.
Action Checklist:
  • List every potentially reportable foreign property held during the year.
  • Determine the applicable cost amount for each item.
  • Aggregate the cost amounts at the relevant times during the year.
  • If the aggregate exceeded $100,000 at any point, determine whether Part A, Part B or an available aggregate Category 7 method applies.
  • File the T1135 separately by the applicable information-return deadline.

2. What counts as specified foreign property?

Specified foreign property generally includes funds or intangible property situated, deposited or held outside Canada, shares of non-resident corporations other than certain foreign affiliates, interests in certain non-resident entities, indebtedness owed by non-residents, interests in foreign insurance policies and certain other property described in subsection 233.3(1) of the Income Tax Act.

Key Framework Highlights:
  • Foreign currency by itself does not make a Canadian property foreign property; the statutory definition focuses on the property and where it is situated, deposited or held.
  • Property that does not produce income can still be specified foreign property.
  • The precise legal category matters when determining whether an item belongs on T1135.
PropertyGenerally reportable?Important qualification
Foreign bank or investment accountYesFunds outside Canada can be specified foreign property.
Shares of a non-resident corporationYesIncludes foreign securities held through Canadian or foreign brokers unless another statutory exclusion applies.
Foreign rental real estateOften yesForeign real property that is not personal-use property can be specified foreign property; the facts matter.
Foreign vacation property used primarily personallyNoPersonal-use property is excluded.
Property used exclusively in an active businessNoThe active-business exclusion can apply.
Interest in a foreign affiliateNo under T1135Foreign-affiliate information is generally handled under separate reporting rules such as Form T1134.
Foreign insurance policyPotentially yesA life insurance policy issued by a foreign issuer can be specified foreign property.

3. The $100,000 cost-amount threshold

The threshold is crossed when the aggregate cost amount of specified foreign property is more than $100,000 at any time during the year. Cost amount is generally based on the statutory cost concept and, for capital property, commonly corresponds to adjusted cost base rather than current fair market value.

ExampleAggregate cost amountT1135 result
Foreign shares $70,000 + foreign bank account $35,000$105,000T1135 required because aggregate cost exceeds $100,000.
Foreign property reaches $125,000 in March and falls to $80,000 in December$125,000 at some point during the yearT1135 required; the year-end amount being below $100,000 does not remove the obligation.
Foreign securities cost $90,000 but year-end fair market value is $140,000$90,000 cost amountThe $100,000 T1135 threshold is not crossed solely because FMV is $140,000.
Foreign rental property cost $180,000 and mortgage financing is $130,000$180,000 cost amount, subject to the applicable cost rulesFinancing does not reduce the property's cost amount to the down payment.

4. Part A simplified reporting vs Part B detailed reporting

CRA provides two main reporting methods based on the total cost amount during the year. Part A is available when the total cost amount of specified foreign property was more than $100,000 but remained below $250,000 throughout the year. Part B is required when the total cost amount was $250,000 or more at any time during the year.

SituationMethodGeneral information required
No more than $100,000 of specified foreign property cost amount at all timesNo T1135 generally requiredDo not file solely because foreign property exists.
More than $100,000 and always less than $250,000Part A — Simplified reportingReport applicable property categories, top three country codes based on aggregate maximum cost, total income and gain/loss information.
$250,000 or more at any timePart B — Detailed reportingReport required details for the specified foreign property, including the relevant maximum cost, income and gain/loss information.

5. Category 7: foreign securities held through a Canadian brokerage

Foreign securities held in an account with a Canadian registered securities dealer or a qualifying Canadian trust company can be reported using the aggregate method in Category 7. This is an important exception to the assumption that every foreign share must always be listed individually.

Key Framework Highlights:
  • Shares of non-resident corporations are generally specified foreign property even when held through a Canadian brokerage.
  • The fact that a Canadian brokerage holds the securities does not make the foreign shares Canadian property.
  • Where the statutory Canadian registered-dealer or trust-company conditions are satisfied, Category 7 allows aggregate reporting on a country-by-country basis.
  • The aggregate method uses the applicable fair-market-value information and aggregate income and disposition gain/loss information required by the form.
  • The financial institution should be asked whether it qualifies as a Canadian registered securities dealer or qualifying Canadian trust company for T1135 purposes.
Holding arrangementT1135 treatment
U.S. shares in a non-registered account at a qualifying Canadian registered securities dealerGenerally reportable; Category 7 aggregate reporting may be available.
U.S. shares in a foreign brokerage accountGenerally reportable as specified foreign property; Category 7 Canadian-dealer aggregate treatment does not apply merely because the broker is a foreign institution.
Canadian-company shares held at a Canadian brokerageThe shares themselves are not foreign shares merely because the account also contains U.S. securities.

6. Registered plans and important exclusions

CRA excludes specified foreign property held in several Canadian registered plans from T1135 reporting. CRA's current guidance expressly identifies RRSPs, PRPPs, RRIFs, RPPs and TFSAs as excluded from T1135 reporting. The exclusion is statutory and should not be generalized to every registered or tax-advantaged account without checking the specific legislation.

Account or propertyT1135 treatment under CRA guidance
RRSPForeign property held inside the RRSP is excluded from T1135 reporting.
PRPPForeign property held inside the PRPP is excluded.
RRIFForeign property held inside the RRIF is excluded.
RPPForeign property held inside the RPP is excluded.
TFSAForeign property held inside the TFSA is excluded.
Ordinary non-registered accountForeign securities and other specified foreign property can be reportable.

7. Foreign real estate and personal-use property

Foreign real estate requires a fact-specific analysis. Personal-use property is excluded from specified foreign property. CRA states that it generally considers property to be personal-use property when it is used primarily for personal use or enjoyment, with 'primarily' generally meaning more than 50%. A foreign property that is rented for profit and is not primarily personal-use can therefore become reportable.

Foreign real-estate situationGeneral T1135 result
Florida vacation home used primarily for personal enjoymentGenerally excluded as personal-use property.
Foreign condominium rented for most of the year with a reasonable expectation of profit and used personally for a minority of the yearGenerally reportable because it is not primarily personal-use property.
Foreign vacation property rented occasionally only to recover part of the costs, with no reasonable expectation of profitCRA may continue to treat it as personal-use property, depending on the facts.
Foreign multi-unit property with most units rented for profit and one unit personally usedThe overall property can still be reportable because it is not primarily personal-use property.

8. New immigrants, emigrants and residency changes

Special rules apply when a taxpayer becomes or ceases to be a Canadian resident. CRA states that an individual who becomes resident in Canada for the first time does not have to file T1135 for the tax year in which residency first begins. For future years, CRA generally uses the fair market value of specified foreign property at the time residency begins as the relevant starting cost amount for the new resident.

Key Framework Highlights:
  • First Canadian-resident year: CRA says an individual generally does not have to file T1135 for the year in which they first become resident in Canada.
  • Future-year cost basis: CRA generally uses the fair market value of the foreign property when the taxpayer first becomes resident as the relevant cost amount for future T1135 calculations.
  • Emigration: CRA states that an emigrant's reporting is limited to the period of Canadian residency for that year under its administrative guidance.
  • Residency status should be established before applying the T1135 threshold.
Action Checklist:
  • Determine the exact Canadian-residency start or end date.
  • Separate property owned before residency from property acquired afterward.
  • For a new resident, document the fair market value of relevant foreign property on the residency date.
  • For an emigrant, determine the period for which T1135 reporting is required.

9. Important exclusions beyond registered plans

T1135 reporting is limited to property that fits the statutory definition of specified foreign property. Several important exclusions can prevent a foreign asset from being reportable even when it is expensive.

Potential propertyExcluded?Reason
Property used or held exclusively in carrying on an active businessGenerally yes, excludedActive-business exclusion
Personal-use propertyYes, excludedPersonal-use exclusion
Shares of a foreign affiliateYes, excluded from T1135Separate foreign-affiliate reporting can apply
Canadian resident mutual fundGenerally no T1135 for the Canadian mutual fund itselfIt is not specified foreign property merely because it invests abroad
Non-resident mutual fundGenerally yes, the investment itself can be specified foreign propertyReport the interest in the non-resident fund rather than automatically tracing every underlying investment

10. Filing deadlines for T1135

For individuals, corporations and trusts, Form T1135 is generally due on the same date as the related income-tax return. For individual taxpayers, the practical deadlines are generally April 30, or June 15 where the taxpayer or their spouse or common-law partner carried on a business in the year, subject to the specific rules. Corporations generally have six months after the end of the fiscal period. Partnerships have a separate deadline tied to their partnership information return.

TaxpayerGeneral T1135 deadline
Individual, no qualifying business situationApril 30
Individual where taxpayer or spouse/common-law partner carried on businessJune 15
CorporationSix months after fiscal year-end
PartnershipGenerally the same deadline as the partnership information return under the applicable rules
Deceased individualSpecial due-date rules can apply

11. Late-filing and false-statement penalties

T1135 is an information return with its own penalty regime. The ordinary failure-to-file penalty is $25 per day, subject to a minimum $100 and a maximum $2,500. More serious penalties can apply where the failure to file or inaccurate reporting is knowing or amounts to gross negligence, and CRA can impose additional penalties after issuing a demand to file.

SituationPenalty framework
Ordinary failure to file$25 per day, minimum $100, maximum $2,500
Failure to file knowingly or in circumstances amounting to gross negligence$500 per month for up to 24 months, maximum $12,000, less certain penalties already levied
Failure to comply after a CRA demand, in the relevant gross-negligence circumstances$1,000 per month for up to 24 months, maximum $24,000, less certain penalties already levied
After 24 months in the relevant circumstancesAn additional 5% penalty can apply based on the statutory amount described by CRA
Knowingly or with gross negligence making a false statement or omissionA separate false-statement/omission penalty can apply; for T1135, CRA's penalty table refers to the greater of $24,000 or 5% of the relevant cost amount, subject to the statutory rules.

12. How T1135 reporting works for common assets

AssetTypical treatmentKey issue
U.S. shares in non-registered Canadian brokerageGenerally reportableCanadian broker does not make the foreign shares Canadian; Category 7 aggregate reporting may be available.
U.S. bank accountGenerally reportableFunds deposited outside Canada are specified foreign property.
Foreign rental condominiumPotentially reportablePersonal-use and profit facts matter.
Foreign vacation home used primarily personallyGenerally excludedPersonal-use property exclusion.
Foreign shares in RRSPExcludedRegistered-plan exclusion.
Foreign shares in TFSAExcludedRegistered-plan exclusion.
Interest in foreign affiliateExcluded from T1135Separate Form T1134 rules may apply.

13. T1135 filing workflow

T1135 preparation should be done as a separate foreign-reporting exercise even when the taxpayer is also preparing a T1 or corporate tax return.

Action Checklist:
  • Step 1 — Determine whether you were a Canadian resident for the relevant period.
  • Step 2 — Identify all foreign assets and interests held at any time during the year.
  • Step 3 — Classify each item under the statutory specified-foreign-property definition.
  • Step 4 — Remove statutory exclusions such as qualifying registered-plan holdings, personal-use property, active-business property and foreign-affiliate interests.
  • Step 5 — Determine the cost amount of each reportable item and aggregate it to test the $100,000 threshold.
  • Step 6 — Determine whether Part A or Part B applies; check whether Category 7 aggregate reporting is available for Canadian brokerage holdings.
  • Step 7 — Gather country codes, maximum amounts, year-end amounts, income and disposition gain/loss information required by the applicable part.
  • Step 8 — File the T1135 by the correct deadline for the taxpayer type.
  • Step 9 — Keep supporting statements, transaction records, valuations and foreign tax documents with the tax records.
  • Step 10 — If a prior T1135 was missed or inaccurate, consider whether an amendment or the Voluntary Disclosures Program is appropriate rather than ignoring the omission.

14. 2026 T1135 examples

ScenarioResult
Canadian resident has U.S. shares costing $80,000 and a U.S. bank account of $30,000Aggregate cost $110,000; T1135 is required.
Canadian resident's foreign assets peak at $140,000 in May but fall to $60,000 by year-endT1135 is still required because the threshold was exceeded during the year.
Canadian resident holds $180,000 of foreign securities all yearPart A simplified reporting is generally available because the total remained below $250,000.
Canadian resident's specified foreign property reaches exactly $250,000Part B detailed reporting applies because $250,000 or more falls into the detailed tier.
New immigrant becomes resident during 2026 with $300,000 of foreign investments already ownedCRA generally does not require T1135 for the first year of Canadian residence; future-year cost calculations generally start from the FMV at the residency date.
U.S. shares worth $200,000 are held in a Canadian RRSPThe shares are generally excluded from T1135 because the specified foreign property is held inside an excluded registered plan.
Florida condo is used personally 80% of the time and rented 20% of the time without a reasonable expectation of profitCRA would generally view it as personal-use property, subject to the facts.

15. 2026 T1135 decision framework

Action Checklist:
  • Are you a Canadian-resident taxpayer or another person/entity within the T1135 rules?
  • Did specified foreign property exceed $100,000 of aggregate cost amount at any time during the year?
  • Is any property excluded because it is personal-use, active-business property, foreign-affiliate property or held inside an excluded registered plan?
  • Are foreign securities held through a Canadian registered securities dealer or qualifying trust company so Category 7 aggregate reporting may be available?
  • Did the aggregate cost reach $250,000 or more at any time, requiring Part B detailed reporting?
  • Did you become a Canadian resident during the year and qualify for the first-year exemption?
  • Did you cease Canadian residency during the year and need to limit reporting to the Canadian-resident period under CRA's guidance?
  • Are you filing for an individual, corporation, partnership or trust with a different deadline?
  • Are you dealing with a prior missed T1135, incomplete return or false statement that may require corrective action?
  • Have you retained the cost-base, valuation, income and disposition records supporting the T1135?

Frequently Asked Questions

Generally, when the taxpayer owns specified foreign property whose aggregate cost amount was more than $100,000 at any time during the year. The test is based on cost amount rather than fair market value, and the threshold is tested during the year rather than only at year-end.

Generally yes. Shares of non-resident corporations are specified foreign property even when held through a Canadian broker. If the securities are held through a qualifying Canadian registered securities dealer or Canadian trust company, Category 7 aggregate reporting may be available instead of listing every security individually.

CRA expressly excludes specified foreign property held in RRSPs, PRPPs, RRIFs, RPPs and TFSAs from T1135 reporting. Do not automatically extend that exclusion to other registered accounts without checking the current statutory rules for that account.

No. Personal-use property is excluded, but CRA generally looks at whether the property is used primarily for personal use or enjoyment. CRA states that 'primarily' generally means more than 50%. A foreign property rented for profit and not primarily personal-use can be reportable.

The ordinary penalty is $25 per day, with a minimum $100 and maximum $2,500. A knowing or gross-negligent failure can trigger $500 per month for up to 24 months, and after a CRA demand a higher $1,000-per-month penalty can apply in the relevant circumstances. Other penalties can apply for false statements or omissions.

Part A is the simplified method for taxpayers whose specified foreign property cost amount was more than $100,000 but remained below $250,000 throughout the year. Part B is the detailed method when the total cost amount was $250,000 or more at any time during the year. Category 7 can provide a separate aggregate reporting option for qualifying Canadian brokerage accounts.

Official Government & CRA References

2026 T1135 Key Metrics

  • Filing threshold
    More than $100,000 of aggregate cost amount at any time in the year
  • Part A simplified method
    More than $100,000 but throughout the year less than $250,000
  • Part B detailed method
    $250,000 or more at any time in the year
  • Basic late-filing penalty
    $25/day, minimum $100, maximum $2,500

Related Tax Tools

CRA Voluntary Disclosures Program (VDP) Guide→Foreign Tax Credit & Treaty Calculator→TFSA Non-Resident Rules Guide→

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