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Form T1135 is due when foreign property costs more than $100,000. Whether crypto on a foreign platform counts is not confirmed on the CRA pages we read, because they never mention it. Budget 2026 proposes $200,000 from 2027. Until then, cost in Canadian dollars is the test.
What is T1135 foreign reporting?
Form T1135, the Foreign Income Verification Statement, is an information return. It is for Canadian resident individuals, corporations and certain trusts and partnerships that owned specified foreign property costing more than $100,000 at any time in the year. Filing it does not mean you owe tax. It tells the CRA what you hold abroad.
The CRA T1135 page (page dated 19 October 2026) lists what counts as specified foreign property. The list includes funds or intangible property situated, deposited or held outside Canada, shares of non-resident corporations, debts owed by non-residents, and some other items. The test uses cost, in Canadian dollars, not today's market value. From $100,000 up to under $250,000 the simplified Part A is available, and at $250,000 or more the detailed Part B applies. The form is due with your return: 30 April, or 15 June if you or your spouse or common-law partner run a business. Our general guide to US stocks, the foreign tax credit and T1135 shows how the form works for ordinary investments.
Does crypto held abroad count as foreign property?
This is the unclear part. The CRA T1135 page, dated 19 October 2026, does not mention cryptocurrency. We saw no T1135 mention in the CRA crypto guide pages we read either. The T1135 form page dated 14 November 2024 does not mention crypto.
The general wording is where the question comes from: "funds or intangible property situated, deposited or held outside Canada". Some practitioner commentary applies that wording to coins held on a platform located abroad. We could not confirm that view on a CRA page, so we do not state it as the CRA's position. The CRA also does not say, in the pages we read, where a coin is "situated" when it sits in a wallet and only a private key proves control.
| Situation | Is it on the T1135 list? |
|---|---|
| Coins on a platform based outside Canada | Not confirmed on a CRA page |
| Coins on a platform based in Canada | Not confirmed, and the platform location test is not spelled out |
| Coins in your own hardware or software wallet | Not confirmed |
| Cash in a foreign bank account used to buy coins | Yes, a foreign bank deposit is on the list |
| Shares of a foreign crypto company | Yes, shares of non-resident corporations are on the list |
If you are close to the line, ask the CRA or a tax professional before you decide not to file, because a failure to file carries significant penalties. We cannot tell you which way a particular holding falls.
How is cost counted toward the $100,000 line?
The line is about what you paid, in Canadian dollars, for all specified foreign property together. It looks at the highest total at any time in the year, as the CRA describes it with the words "at any time during the year". Cost generally means the amount you paid including fees, converted to Canadian dollars on the day of each purchase. Our crypto tax guide explains cost and the adjusted cost base.
Two illustrations, with made up numbers. First, you hold coins that cost $60,000 on one foreign platform and $55,000 on another. If both count, the total cost is $115,000, which is over $100,000. Second, you hold coins that cost $90,000 on a foreign platform and they are now worth $400,000. If the cost test applies, the total cost is $90,000, under $100,000, even though the market value is far higher. The second example shows why records of purchase cost matter more than screenshots of your balance.
A purchase with other coins, a swap or a transfer between your own accounts can change the cost and the location in ways that need care. Keep a ledger of each purchase date and its dollar cost.
What does Budget 2026 propose for the threshold?
The Budget 2026 tax measures annex proposes to raise the threshold above which Form T1135 must be filed from $100,000 to $200,000. It says these measures would apply to taxation years or fiscal periods that end after 2026. The site's article on Budget 2026 also notes that the simplified reporting threshold would rise from under $250,000 to under $500,000.
This is a proposal. Budget measures need legislation and royal assent. Until then, the $100,000 limit is the rule in force. In the first illustration, a total cost of $115,000 stays over $100,000 and would be under the proposed $200,000 limit.
What happens for your 2026 return?
The 2026 tax year ends 31 December 2026. A calendar year 2026 return is filed by 30 April 2027, or 15 June 2027 if you or your spouse run a business, with any tax owing still due 30 April. The T1135 follows the same deadline. The proposed $200,000 threshold applies to years ending after 2026, so it begins with 2027, which is filed in 2028 and not in 2027.
| Tax year | Filing threshold in force or proposed | Status |
|---|---|---|
| 2026 (filed 2027) | $100,000 total cost | In force |
| 2027 (filed 2028) | $200,000 total cost | Proposed in Budget 2026 |
| Simplified method 2026 | Part A under $250,000 | In force |
| Simplified method 2027 | Part A under $500,000 | Proposed, per the site article on Budget 2026 |
With the example of $115,000 in total cost, a person in that position could be required to file for 2026 and not for 2027, if the proposal passes and nothing else changes.
What are the penalties for filing a T1135 late?
The CRA page says there are significant penalties for failing to file by the deadline. The Income Tax Act sets the usual late filing penalty at $25 a day up to $2,500, and there are larger penalties for knowing or grossly negligent omissions. The CRA also has more time to reassess foreign income that was not reported, as our T1135 guide notes. Read the CRA penalties page for the current amounts before you rely on these figures.
If you missed past T1135 filings, our page on CRA reviews and voluntary disclosure explains the route for correcting past years.
This page is information only. We do not give advice, we do not represent the CRA or any organization, and we do not guarantee accuracy.
Frequently asked questions
Do I need to file a T1135 if I hold crypto on a foreign exchange?
It is not confirmed on a CRA page. The T1135 covers funds or intangible property held outside Canada once total cost passes $100,000, but the CRA pages we read do not mention crypto. Some commentary says foreign platform holdings count. Ask the CRA or a professional if you are near the limit.
Is the T1135 test based on market value or cost?
It is based on cost in Canadian dollars, taking the highest total at any time in the year. A holding bought for $90,000 and now worth $400,000 has a cost of $90,000 for this test, if it counts as specified foreign property at all.
What is the proposed new T1135 threshold?
Budget 2026 proposes to raise it from $100,000 to $200,000 of total cost, for tax years or fiscal periods ending after 2026. It is a proposal until it is legislated, so the $100,000 limit still applies to your 2026 return.
When is the T1135 due for 2026?
It is due with your return: 30 April 2027 for most individuals, or 15 June 2027 if you or your spouse or common-law partner carried on a business. Any tax owing is still due 30 April 2027. Corporations file six months after the fiscal period ends.
What is the penalty for not filing a T1135?
The CRA says the penalties are significant. The Income Tax Act sets a late filing penalty of $25 a day up to $2,500, with larger penalties for knowing omissions. Check the CRA penalties page for current figures before relying on them, and ask a professional about any past year.
Does filing a T1135 mean I owe tax on the coins?
No. The T1135 only reports what you hold abroad. Tax on gains or income is worked out separately under the crypto rules, and our crypto tax guides explain those. Filing the form does not change that, but the CRA gets more information about your holdings.