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T1135 Foreign Property Reporting in Canada: Who Must File

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You must file Form T1135 if you are a Canadian resident and the total cost of your specified foreign property was more than $100,000 at any time in the year. It is due with your return. Cost, not market value, is the test. Budget 2026 proposes $200,000, but that is a proposal for later years, not law.

What is Form T1135 and who has to file it?

Form T1135 is the Foreign Income Verification Statement. It is an information return, so filing it does not add tax by itself. It tells the CRA what you own outside Canada. The CRA says Canadian resident individuals, corporations and certain trusts must file it if they held specified foreign property costing more than $100,000 at any time in the year. Certain partnerships have the same duty.

Two details catch people out. The test uses what the property cost you, converted to Canadian dollars, and not what it is worth today. And it adds up everything you hold abroad, at any time in the year. A position you sold in March still counts for that year.

You file it even if no tax is owing. For digital assets, see our page on crypto held abroad and the T1135.

What counts as specified foreign property?

The CRA lists these as specified foreign property:

  • funds or intangible property held outside Canada, such as a foreign bank deposit
  • tangible property located outside Canada, such as a rental condo or vacant land abroad
  • shares of non-resident corporations, and shares of Canadian corporations held outside Canada
  • interests in non-resident trusts acquired for consideration
  • debts owed by non-residents, such as bonds, mortgages and notes
  • interests in foreign insurance policies
  • precious metals, gold certificates and futures contracts held outside Canada

Property that earns no income, such as vacant land, still counts. Shares of non-resident corporations are reportable "regardless of whether the shares are held through a broker", so US stocks bought through a Canadian brokerage account are still on the list. The CRA lets you report holdings kept with a Canadian registered securities dealer or trust company as one line per country.

What is left off the T1135?

The CRA excludes these from the count:

  • personal-use property, such as a vacation home used mainly for personal purposes, or art and jewellery
  • property used or held exclusively in an active business
  • shares or debt of a foreign affiliate
  • specified foreign property held in an RRSP or a TFSA
  • Canadian mutual fund trusts and corporations

The CRA reads "primarily" as more than 50 percent. A condo you use only as a vacation home is left off. A condo you rent for eight months a year with a reasonable expectation of profit, and use yourself for four, is on the form. A condo rented only to cover costs, with no reasonable expectation of profit, is treated as personal-use. Keep rental records. Our page on foreign property tax for Canadian residents covers the income tax side of owning property abroad.

Do I file the simplified Part A or the detailed Part B?

It depends on the highest total cost during the year. The CRA sets the two levels this way:

Total cost of specified foreign propertyWhat you fileWhat it asks
$100,000 or lessNo T1135Nothing to report
More than $100,000 and under $250,000Part A, simplifiedA box for each type of property, total income, total gains or losses
$250,000 or morePart B, detailedEach property, its country, maximum cost, year-end cost, income and gain or loss

Property held in an account with a Canadian registered securities dealer or trust company can use the aggregate method on either part. You report the total by country, using the highest month-end fair market value in the year plus the year-end value, together with the income and the gains or losses.

How does the $100,000 test work in a real example?

Take Maria, a made-up Ontario resident. During 2026 she held US shares bought for $62,000 in a Canadian brokerage account, a US bank account where the balance peaked at $38,000, and a rental condo in Florida that cost her $140,000. She also holds US stocks in her RRSP and owns an Ontario cottage.

HoldingOn the T1135?Cost counted
US shares in a Canadian brokerage accountYes$62,000
US bank account (highest balance)Yes$38,000
Florida rental condo, rented for profitYes$140,000
US stocks inside her RRSPNo, excluded$0
Ontario lake cottageNo, in Canada$0
Total$240,000

The total of $62,000 plus $38,000 plus $140,000 is $240,000. That is above $100,000 and below $250,000, so Maria files the simplified Part A. If she had bought another $15,000 of US shares in the same year, the total would reach $255,000 and she would move to the detailed Part B. All figures are example costs in Canadian dollars.

When is the T1135 due and how do I file it?

The T1135 goes in with your return. The CRA gives these due dates:

  • individuals who are not self-employed: April 30
  • individuals who, or whose spouse or common-law partner, carried on a business: June 15
  • corporations: six months after the fiscal period ends
  • inter vivos trusts: 90 days after December 31

Individuals can file it electronically with EFILE or NETFILE for tax years from 2017. On paper, you attach the form to your return or send it separately to the Winnipeg Tax Centre by the due date. Our page on the May 15 tax filing deadline for 2027 has the return dates.

What are the penalties for a late or wrong T1135?

The CRA table of penalties lists these amounts for Form T1135:

SituationPenalty
Late or missing filing$25 per day for up to 100 days, minimum $100, maximum $2,500
Knowing or grossly negligent failure to file$500 per month for up to 24 months, maximum $12,000, and then 5% of the property cost after 24 months
Knowing or grossly negligent failure after a formal demand to file$1,000 per month for up to 24 months, maximum $24,000
False statement or omission made knowingly or through gross negligenceThe greater of $24,000 or 5% of the property cost

Here are the late filing amounts worked out. At 3 days late the formula gives $75, so the $100 minimum applies. At 20 days it is $500, at 60 days $1,500, and from 100 days on it stops at $2,500. For Maria's $240,000 of cost, a knowing omission would carry the greater of $24,000 or $12,000, which is $24,000. At $600,000 of cost, 5% is $30,000, which is higher.

There is a second cost. If you also failed to report income from specified foreign property and the T1135 was late or inaccurate, the CRA says the normal reassessment period is extended by three years. You can ask for penalty relief in writing on Form RC4288.

What if I missed filing the T1135 in past years?

File the missing forms as soon as you can, and do not wait for a letter. The CRA Voluntary Disclosures Program can reduce penalties and interest if you come forward first. Since October 1, 2025, the CRA says unprompted applications normally get 100% relief of the penalties and 75% relief of the interest, while prompted applications normally get up to 100% penalty relief and 25% interest relief. The tax itself is still owing. You apply on Form RC199, and the application must be complete and include the tax you estimate you owe.

Our page on what the Voluntary Disclosures Program covers explains the steps. Speak to a tax professional before you decide how to file late.

Does a US FBAR replace the T1135?

No. They are separate filings to separate governments, and filing one does not satisfy the other. The T1135 is a Canadian form for Canadian residents. The FBAR, FinCEN Form 114, applies to US persons, such as US citizens living in Canada, who have a financial interest in or signature authority over foreign financial accounts whose combined value exceeded $10,000 at any time in the year, according to the IRS. It is due April 15 with an automatic extension to October 15, and it is filed with FinCEN, not with your tax return. We did not check the IRS Form 8938 rules.

Will the $100,000 threshold go up?

Budget 2026 proposes to raise the T1135 filing threshold from $100,000 to $200,000. The Budget 2026 tax measures also say the CRA would raise the simplified reporting limit from under $250,000 to under $500,000. The page says the measures would apply to taxation years or fiscal periods that end after 2026. A calendar 2026 year ends on December 31, 2026, so our reading is that the new limits would start with 2027, but we have not seen a bill. This is a proposal, not law. For 2026, plan on the $100,000 test and the $250,000 split above. Our page on the proposed T1135 threshold follows the budget wording.

Where does this information come from?

Who files, the property list, exclusions, the Part A and Part B limits and due dates come from the CRA Foreign Income Verification Statement and Form T1135 reporting pages. Property examples and the RRSP and TFSA exclusion come from the CRA questions and answers about Form T1135. Penalty amounts come from the CRA table of penalties. Voluntary disclosure details come from the CRA, the FBAR facts from the IRS, and the proposal from Budget 2026. All were last checked November 12, 2026. The worked example and the penalty arithmetic are our own. This is an independent information site: we provide no services, we do not represent the CRA or any organization, we collect information from open sources, and we do not guarantee that anything here is accurate or current. We accept no liability for decisions based on it.

Frequently asked questions

Do I have to file a T1135 if I only own US stocks in a Canadian brokerage account?

Yes, if the total cost of all your specified foreign property was more than $100,000 at any time in the year. The CRA says shares of non-resident corporations are reportable even when held through a broker. Holdings in an RRSP or TFSA are excluded from the count and the form.

Is the $100,000 based on cost or market value?

It is based on cost. The CRA says the test uses the cost amount, not market value, and it adds up all your specified foreign property at any time in the year. Its example combines $75,000 of shares and a $35,000 US bank deposit, which is $110,000, so a T1135 is required.

Is a vacation home abroad reported on the T1135?

Usually not, if you use it mainly for personal purposes. The CRA treats property as personal-use when you use it primarily for that, and reads primarily as more than 50 percent. A foreign rental condo you rent out with a reasonable expectation of profit is reported, so keep rental records.

What is the penalty for filing the T1135 late?

The CRA table of penalties sets $25 per day for up to 100 days, with a $100 minimum and a $2,500 maximum. Higher penalties apply for knowing or grossly negligent failures and for false statements, including the greater of $24,000 or 5 percent of the property cost.

When is the T1135 due?

It is due with your tax return. The CRA lists April 30 for individuals who are not self-employed and June 15 for individuals who, or whose spouse or common-law partner, carried on a business. Corporations file within six months after the fiscal period ends.

Has the T1135 threshold changed to $200,000?

Not yet. Budget 2026 proposes to raise it from $100,000 to $200,000, and the simplified limit from $250,000 to $500,000, for years ending after 2026. It is a proposal that needs legislation, so use the $100,000 test for 2026 and watch for the bill.

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