The T1135 Foreign Income Verification Statement is a foreign reporting form that collects no tax, yet filing it late draws a charge even when you owe nothing. Plenty of people file it: the CRA’s International Tax Gap and Compliance Results report counts 210,750 individuals who filed for 2014, reporting foreign assets worth about $160 billion.
Key Takeaways
- The $100,000 test measures cost, not market value, at any moment in the year.
- The form is due with your return: April 30 for most individuals, June 15 for self-employed households, and six months after year-end for corporations.
- US shares in a Canadian brokerage count; the same shares inside an RRSP or TFSA do not.
- A vacation home you actually use is excluded; a foreign rental property is reportable.
- Part A covers $100,000 to $250,000, and Part B takes over at $250,000.
- Filing late costs $25 a day to a $2,500 ceiling, even when no tax is owing.
Who Is Required to File Form T1135
You file if you were a resident of Canada for tax purposes and you held specified foreign property costing more than $100,000 at any point in the year. The T1135 reporting requirements apply to corporations, most trusts and certain partnerships too. Note the wording: at any time, not at year-end. Property bought in March and sold in September still triggers the form.
Section 233.7 of the Income Tax Act (ITA) excuses an individual from filing for the year they first become resident in Canada. The word “first” matters: in our reading, if you lived here before, left and later moved back, the year you return is not your first year of residence. Leaving works the other way. If you emigrate partway through a year, the CRA asks only about property you held while resident, although the departure tax rules still apply to the move itself. Non-residents do not file at all.
The T1135 Due Date Follows Your Tax Return
Form T1135 must be filed by the filing deadline for your income tax return or, for a partnership, the deadline for its partnership information return. That deadline stands even in a year when no return is otherwise required, so you must still file the form on time. The Foreign Income Verification Statement page lists the deadline for each kind of filer:
| Who files | Deadline | For a year ending December 31, 2025 |
|---|---|---|
| Individuals | April 30 of the following year | April 30, 2026 |
| Individuals who carried on a business, or whose spouse or common-law partner did | June 15 of the following year | June 15, 2026 |
| Trusts | 90 days after the trust’s year-end | March 31, 2026 |
| Corporations | Six months after the end of the corporation’s year | June 30, 2026 |
| Partnerships whose members are all individuals | March 31 of the following year | March 31, 2026 |
| Partnerships whose members are all corporations | Five months after the fiscal period ends | May 31, 2026 (a Sunday) |
| Other partnerships | The earlier of the two partnership deadlines | March 31, 2026 |
The dates in the last column are our count from those rules. By the same count, the individual deadlines for 2026 are April 30, 2027 and June 15, 2027. The individual code on the form follows the same split: tick 1 if you or your spouse or common-law partner is self-employed, and 2 if neither of you is.
The $100,000 Reporting Threshold Is a Cost Amount, Not Market Value
The test measures cost amount, generally your adjusted cost base (ACB) in Canadian dollars, rather than what the asset is worth today. A US share portfolio you bought for $80,000 that now trades at $190,000 therefore stays below the line. A rental apartment in Portugal you paid $210,000 for sits above it, even after a price slump.
The threshold is also a total, not a per-asset test. In the CRA’s own example, $75,000 of shares in a non-resident corporation plus $35,000 in a US bank account makes $110,000, so the total cost of all specified foreign property exceeds the line and the form is required.
Three adjustments catch people out. Property you owned when you immigrated takes a cost equal to its fair market value on the day you became resident. A gift or inheritance takes its fair market value when you received it, which is how a single inheritance from abroad can carry you over the line in one step. Debt never nets off: if you buy a $500,000 foreign property with a $50,000 down payment, the cost amount of the property is still $500,000.
In our practice, the file that fails is rarely an offshore account. It is a Canadian investor holding US-listed shares in an ordinary self-directed account, contributing steadily, crossing $100,000 in total cost partway through a year nobody was watching.
What Counts as Specified Foreign Property
Subsection 233.3(1) of the ITA sets the definition of specified foreign property, and it reaches well beyond foreign bank accounts. For foreign securities, the issuer’s location decides the answer, not where your account is held.
| Reportable | Not reportable |
|---|---|
| Money in bank accounts and other funds held outside Canada | Anything inside an RRSP, RRIF, TFSA, RESP, FHSA, or registered pension plan |
| Shares of foreign companies, including US shares bought through a Canadian broker | Personal-use property, such as a vacation home you use yourself |
| Shares of Canadian corporations held for you outside Canada | Property used or held exclusively in an active business |
| Foreign rental real estate and vacant land abroad, even when it earns nothing | Shares of, or debts owed by, a foreign affiliate, which Form T1134 covers |
| Debts owed to you by a non-resident, including foreign government and corporate bonds | Units of Canadian mutual funds and Canadian ETFs, even when they own foreign stocks |
| Interests in non-resident trusts acquired for value, such as units of an offshore fund | US dollars in an account at a Canadian bank |
| A foreign insurance policy, precious metals held abroad, and intangible property such as a patent situated outside Canada | Personal effects abroad, such as a car or artwork you use |
The most common misreading involves investment accounts. US shares bought through a Canadian broker are reportable, while identical shares inside your RRSP or TFSA never reach this form. For country codes, the issuer’s country of residence decides, so US shares held in a UK brokerage account are coded USA.
Foreign Real Property: When a Vacation Home Becomes Reportable
Foreign real property is where the personal-use exception does the heavy lifting. Property held primarily for personal use or enjoyment falls outside the definition, so a Florida condo your family uses only as a vacation property stays off the form. That is the CRA’s own example.
Renting changes the analysis. The official questions and answers on Form T1135 treat a unit rented eight months a year with a reasonable expectation of profit, and used personally for the other four, as reportable. A four-unit building abroad with one unit for your own use and three rented out is reportable at its entire cost, where the units are roughly equal in size and value. Once you rent, the rent belongs on your return as well, which our guide to foreign rental income walks through.
Cost also counts only from the moment title passes. A $500,000 pre-construction unit you have paid $50,000 toward stays off the form until title transfers to you.
Simplified Reporting vs the Detailed Reporting Method
The form offers two paths. Part A is open to you when total cost stayed above $100,000 but under $250,000 all year, and you can still choose Part B instead. In Part A, you tick each type of property you held, enter your top three countries by maximum cost amount, and report gross income and the gain or loss on dispositions as single totals.
Part B takes over once cost touches $250,000 at any moment, even if the balance falls back before December 31. There you list each property in one of seven categories with its country code, maximum cost amount during the year, year-end cost amount, gross income, and any capital gain or loss on disposition. The maximum can be based on month-end figures, and once you choose Part B, you use it for every property.
Specified foreign property held with a Canadian registered securities dealer or a Canadian trust company earns relief. Category 7 lets you report it in aggregate, country by country, using the highest month-end fair market value and the year-end value instead of cost.
How to Complete Form T1135 and File It
Most of the work on the T1135 form is gathering cost and income figures. Work through it in this order:
- Answer the foreign property question at line 26600 of your T1 return (line 266 on returns for 2018 and earlier). For 2025, it asks whether the total cost amount of all your specified foreign property, at any time in 2025, was more than CAN$100,000.
- Tick the box for who is reporting (individual, corporation, trust or partnership), enter the year, and choose your individual or partnership code.
- Tick Part A or Part B, based on your highest combined cost during the year.
- Work out each amount in the foreign currency, then convert it to Canadian dollars, generally at the rate on the day of the purchase or receipt. An average rate for the year is acceptable for income received throughout the year and applies to maximum balances, while year-end balances take the year-end rate.
- Report gross income, not net, round to the nearest dollar, and enter 0 rather than leaving a field blank.
- File it electronically with certified tax software, or on paper: attach it to your paper return, or mail it on its own to the Winnipeg Taxation Centre.
Individuals can file Form T1135 electronically, through EFILE or NETFILE, for 2017 and later years. Corporations can file Form T1135 through EFILE for the 2014 and later tax years, partnerships from 2017, and trusts from 2021. The current version, T1135 E (23), says it must be used for 2015 and later years, so a late form for 2021 goes on that same version, which sits on the Form T1135 page.
To fix a form you already sent, file an amended T1135 with the amended-return box ticked and every required field completed again. Our personal tax return team prepares the form alongside the T1 so the two never disagree.
The Penalty for Late Filing of T1135
Filing late draws an automatic charge under ITA 162(7): $25 a day for up to 100 days, with a $100 minimum, which caps it at $2,500 per year. The Canada Revenue Agency applies it whether or not you owed a cent of tax, which is exactly why the form feels so punishing. Four late years at that cap come to $10,000 before interest, by our arithmetic.
From there it escalates. The CRA’s summary table sets out the steps, and the ITA supplies the detail:
| What went wrong | What it costs | ITA |
|---|---|---|
| Filing late | $25 a day for up to 100 days, minimum $100, maximum $2,500 | 162(7) |
| Not filing, knowingly or through gross negligence | $500 a month for up to 24 months, maximum $12,000, less the late-filing charge | 162(10) |
| Ignoring a demand to file, knowingly or through gross negligence | $1,000 a month for up to 24 months, maximum $24,000, less the late-filing charge | 162(10) |
| Still unfiled after 24 months in either of those cases | A further 5% of the highest combined cost amount during the year, less the charges above | 162(10.1) |
| Making a false statement or omission, knowingly or through gross negligence | The greater of $24,000 and 5% of the highest combined cost amount during the year | 163(2.4) |
Separately, ITA 152(4)(b.2) gives the Agency three extra years beyond the normal reassessment period when two failures meet. The form was not filed by the reporting deadline or left out required information, and your return fails to report income from that property. Subsection 152(4.01) confines most late reassessments to the items at issue but does not list paragraph (b.2), so in our reading the whole year can be reopened, not only the foreign income.
Relief exists. Under ITA 220(3.1), the Agency can waive or cancel charges and interest within ten calendar years after the end of the year concerned, and our guide to CRA interest and relief explains how that works. The escalated charges are unpacked in our guide to gross negligence penalties.
The Voluntary Disclosures Program is the other route, and the CRA says it may be available for a missed or incomplete T1135. For applications received on or after October 1, 2025, coming forward before the Agency contacts you can bring full relief from charges and 75% of the interest, while a prompted application can bring up to full relief from charges and 25% of the interest. Both routes are formal applications with real evidentiary standards, which is where our CRA representation work begins.
Frequently Asked Questions
Who needs to file T1135?
You need to file if you are resident in Canada and your specified foreign property cost more than $100,000 in total at any point during the year. Corporations, most trusts and certain partnerships face the same test. An individual does not file for the year they first become resident in Canada, under ITA 233.7.
When is T1135 due?
Form T1135 is due on the same day as your tax return. For 2025, that is April 30, 2026 for most individuals, or June 15, 2026 if you or your spouse or common-law partner carried on a business. Corporations file within six months of their year-end, and trusts within 90 days of theirs.
What happens if you do not file T1135?
You are charged $25 for each day the form is late, from a $100 minimum to a $2,500 maximum per year, whether or not tax was owing. Knowing or grossly negligent failures cost $500 a month up to $12,000, or $1,000 a month up to $24,000 after a demand to file. If foreign income also went unreported, the reassessment window stays open three extra years.
Do I still file T1135 if I sold the property before year-end?
Yes. If the combined cost passed $100,000 at any time in the year, you report all the specified foreign property you held during the year. That holds even if you owned less, or nothing, on December 31.
Do I have to report US stocks held in a Canadian brokerage account?
Yes. Shares of foreign corporations are specified foreign property no matter where the account is held, so a Canadian brokerage offers no shelter. Where those securities sit with a registered dealer or trust company in Canada, Category 7 lets you report them by country in aggregate.
Does foreign property in my RRSP or TFSA count toward the threshold?
No. Property held inside an RRSP, RRIF, TFSA, RESP, FHSA, or registered pension plan does not count toward the $100,000 test and is never reported on Form T1135. That is why two investors with identical holdings can face completely different filing obligations.
What is the individual code on Form T1135?
Tick 1 if you or your spouse or common-law partner is self-employed, and tick 2 if neither of you is. The code sits in the identification area on the first page, next to your social insurance number.
Why does my notice of assessment remind me about Form T1135?
The reminder appears automatically whenever your return said your specified foreign property cost more than $100,000. It does not mean your form went missing. The question sits at line 26600 of the return (line 266 before 2019), and you answer it fresh each year.
How does CRA know about my foreign income?
The CRA receives financial account information automatically from the United States, under an intergovernmental agreement signed in 2014, and from partner jurisdictions under the Common Reporting Standard. Banks also report international electronic funds transfers of $10,000 or more, whether the money leaves Canada or arrives from abroad.
The Bottom Line
- Track cost, not value, and test it at the year’s highest point rather than at December 31.
- File by your return’s deadline: April 30 for most individuals, June 15 for self-employed households.
- Check where the issuer sits, not where your account sits.
- Separate the vacation home you use from the property you rent for profit, and keep the evidence.
- File on time even on estimates, because the daily charge does not care why you were late.
Most problems surface years later, usually when a bank statement or an inheritance appears during another review. If a holding might cross the line, or a past year is already missing, contact us and we will map the exposure before an auditor does.
