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Budget 2026 proposes to raise the T1135 filing threshold from $100,000 to $200,000 of foreign property cost, and the simplified reporting limit from $250,000 to $500,000, for years ending after 2026. It is a proposal, not law. Until it passes, the $100,000 test applies.
What does Budget 2026 propose for the T1135?
Budget 2026, tabled on November 5, 2026, proposes to double the cost threshold that triggers Form T1135, the Foreign Income Verification Statement. The tax measures document describes two changes.
| Rule | Today (CRA) | Proposed (Budget 2026) |
|---|---|---|
| Need to file when total cost of specified foreign property is above | $100,000 | $200,000 |
| Simplified reporting available when total cost is below | $250,000 | $500,000 |
The simplified threshold is set by the CRA on the form, not by the Income Tax Act, and the budget says the CRA would raise it. Both changes would apply to taxation years or fiscal periods ending after 2026. These are proposals, not law, and the details could change.
Is the higher threshold in force?
No. As of November 12, 2026, the measure sits in the Budget 2026 tax measures and the related notice of ways and means motion. We found no bill that has passed, and Parliament has to pass one before the Income Tax Act changes. The CRA form and guide still show the current thresholds.
The timing has a practical meaning. Our reading of "ending after 2026" is that the 2026 calendar year is not covered, because it ends on December 31, 2026. If that is right, you still use the $100,000 test on the T1135 you file in 2027 for 2026, and the new thresholds would first apply to the 2027 year, filed in 2028. Confirm the wording when the bill appears.
Who has to report specified foreign property on a T1135 today?
The CRA says Canadian resident individuals, corporations and certain trusts must file if they owned specified foreign property costing more than $100,000 at any time in the year. Certain partnerships do too. The test uses cost, not current market value, and it counts the total across all your foreign property at any time in the year, not the year-end balance.
Specified foreign property, under subsection 233.3(1) of the Income Tax Act, includes funds or intangible property held outside Canada, foreign tangible property, shares of non-resident corporations, interests in non-resident trusts acquired for consideration, debts owed by non-residents, interests in foreign insurance policies, and precious metals or futures held outside Canada. The CRA lists exclusions such as property used in an active business, shares or debt of foreign affiliates, and personal-use property. A newly arrived resident does not file for the first year of residence. Read the CRA page on the Foreign Income Verification Statement for the full list.
Our article on US stocks, the foreign tax credit and the T1135 shows how a Canadian investor's US shares are counted, and the foreign property tax page gives wider context.
How would reporting change at different amounts?
The table applies the CRA rules as they read today and the proposed ones to five made-up total costs. It is an illustration with example figures. The boundaries assume the proposed test keeps the same "more than" wording, which we have not seen in a bill.
| Total cost of specified foreign property | Today | If proposed rules pass |
|---|---|---|
| $80,000 | No T1135 | No T1135 |
| $150,000 | Part A, simplified | No T1135 |
| $220,000 | Part A, simplified | Simplified |
| $400,000 | Part B, detailed | Simplified |
| $600,000 | Part B, detailed | Detailed |
The middle rows show who gains. At $150,000 you file a simplified Part A today and nothing under the proposal. At $400,000 you file the detailed Part B today and the simplified version under the proposal. The simplified method lets you tick a box for each type of property instead of listing each one, while you still report total income and total gains or losses.
What do the simplified and detailed forms ask for?
Under the simplified method, the CRA says you check a box for each type of property held during the year rather than detailing each property. You still report the total income and the total gains or losses from all specified foreign property.
Under the detailed method, you give information on each property: the type, the country, the maximum cost during the year, the cost at year end, the income and the gain or loss. A holding in an account with a Canadian registered securities dealer or trust company can be reported by an aggregate method, by country, using the highest month-end value and the year-end value, as the CRA describes. Keep monthly statements, purchase records and the exchange rates you used so that the numbers can be rebuilt.
When is the T1135 due, and what if I miss it?
The T1135 is due with your return. The CRA lists April 30 for individuals who are not self-employed and June 15 for those who, or whose spouse or common-law partner, carried on a business. Corporations file within six months after the fiscal period ends.
The CRA page says significant penalties may apply for late filing or for false statements and omissions, and it points to its table of penalties instead of listing amounts, so we do not quote a figure here. If you realize you missed a past year, read our guide on CRA taxpayer relief and look at the CRA's voluntary disclosure information before you file late.
Does this matter for crypto and foreign accounts?
Whether a given digital asset or foreign account is specified foreign property is a separate question that depends on the CRA position for that asset. The higher threshold would only change the dollar line, not what counts as specified foreign property. Our hub on crypto tax in Canada covers the tax rules for digital assets.
One more practical point: the cost test counts every foreign holding together, across all your accounts, and it looks at the highest total reached during the year, not the balance on December 31. Someone who bought and sold a large position in the spring can cross the line even if the year-end total is small. That is why a monthly list of foreign holdings, with cost and currency, is worth keeping. The budget text we read mentions only a higher line and no change to how cost is counted.
Plan on the current $100,000 test for 2026 and treat the proposed $200,000 as a possible change for 2027 and later years.
Where does this information come from?
The proposed thresholds and the start year come from the Department of Finance Budget 2026 tax measures supplementary information, checked on November 12, 2026. Today's rules, who files and due dates come from the CRA pages on the Foreign Income Verification Statement and Form T1135 reporting, checked in November 2026. The table and our reading of "ending after 2026" are our own work. 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
What is the current T1135 threshold?
You must file Form T1135 if the total cost of your specified foreign property was more than $100,000 at any time in the year. Cost under $250,000 can use the simplified Part A, and $250,000 or more uses the detailed Part B, per the CRA page.
What does Budget 2026 propose?
It proposes to raise the filing threshold from $100,000 to $200,000 and the simplified reporting threshold from under $250,000 to under $500,000. The changes would apply to taxation years or fiscal periods ending after 2026. They are proposals until Parliament passes legislation.
Do I use the new threshold for my 2026 return?
Probably not. The proposal applies to years ending after 2026, and a calendar year 2026 ends on December 31, 2026. Use the $100,000 test for the T1135 you file in 2027. Check the bill wording when it appears, because this is our reading only.
Is the threshold based on market value?
No, it is based on the total cost of the property, counted at any time during the year. A portfolio that has grown in value can still sit under the cost line, and one bought for more than it is worth now can sit over it. Keep purchase records.
What is the penalty for not filing a T1135?
The CRA page says significant penalties may apply for late filing and for false statements or omissions, and refers to its table of penalties. We did not confirm a dollar figure there, so check the CRA penalty table or ask the CRA before filing late.
Does a Canadian broker account with US stocks count?
It can. Shares of a non-resident corporation are specified foreign property even when held through a Canadian broker, and the CRA offers an aggregate reporting method for such accounts. Read the CRA page or our US stocks article, since exceptions exist for some funds and registered plans.