How is the $100,000 T1135 threshold actually calculated?
The test is: did the total cost amount of your specified foreign property exceed CA$100,000 at any time during the tax year? If yes, you file Form T1135 (Foreign Income Verification Statement) with your return. Three words do all the heavy lifting β cost (not market value), total (everything added together, converted to Canadian dollars), and at any time (not a year-end snapshot). Newcomers are the ones who trip on this most: money sitting in a home-country bank app, a foreign brokerage, and cash lent to a relative abroad all count toward the same $100,000.
Cost, not market value β and "any time," not year-end
Imagine your foreign stock portfolio cost you $110,000, then fell to $90,000 by December 31. You still file. The threshold is measured on cost amount β what you paid, in Canadian dollars β and it is tested continuously through the year. Crossing $100,000 for a single day triggers the filing requirement, even if you sold everything before year-end.
A quick self-test: add up the cost (in CAD equivalent) of every specified foreign property you held at any point in the year. Over $100,000 β file.
What counts toward the $100,000
| Counts (specified foreign property) | Does not count |
|---|---|
| Funds in foreign bank accounts (including e-wallet balances held abroad) | Property you use mainly for personal use (e.g., a vacation home you live in yourself) |
| Shares and bonds of non-resident issuers β including US-listed stocks and ETFs held in a Canadian brokerage's taxable account | Property used in an active business |
| Amounts owed to you by non-residents (loans to relatives or friends abroad) | Holdings inside registered accounts: RRSP, TFSA, RRIF, RESP, FHSA, RDSP β regardless of how much foreign exposure sits inside |
| Interests in foreign trusts or estates | |
| Life insurance policies issued by a foreign issuer | |
| Foreign real estate held for investment (e.g., a rental property) |
Two traps worth highlighting. First, "foreign" follows the issuer, not the account or the currency: Apple shares bought through TD Direct Investing in Canadian dollars are still specified foreign property. Second, everything is converted to Canadian dollars and totalled β it is one $100,000 test across all your foreign property, not $100,000 per account or per asset.
Worked example: a newcomer couple's first full year
| Property | Cost (CAD equivalent) |
|---|---|
| Home-country bank savings account | $28,000 |
| Foreign stocks in a taxable account (cost, not current value) | $50,000 |
| Money lent to a sibling abroad | $35,000 |
| Foreign stocks inside the RRSP | $0 (excluded) |
| Total | $113,000 β T1135 required |
Note the RRSP line: foreign holdings inside a registered account are completely excluded from the test. Move the same stocks into a taxable account and they count.
How the form is filed
T1135 is filed with your income tax return by the return's filing deadline. The form has two reporting methods based on your total cost: a simplified method (Part A) for total cost between $100,000 and $250,000, and a detailed method (Part B) β property-by-property maximum cost, year-end cost, income and gains β for total cost of $250,000 or more.
Late filing is expensive for a form that creates no extra tax: $25 per day up to $2,500 under subsection 162(7). If CRA finds the failure was knowing or grossly negligent, penalties rise to $500 per month for up to 24 months ($12,000 maximum) under subsection 162(10).
Frequently asked questions
I crossed $100,000 in March but sold everything by December. Do I still file?
Yes. The test is "at any time during the year," not at year-end. If your total cost exceeded $100,000 for even one day, the filing requirement applies to that tax year.
My foreign stocks are all inside my RRSP. Do they count?
No. Property held inside an RRSP, TFSA, RRIF, RESP, FHSA, or RDSP is excluded from the T1135 test entirely, no matter how much foreign exposure it holds.
If I am under $100,000, can I ignore foreign income on my return?
No β and this is the companion mistake. The T1135 threshold only decides whether you file the form; it never exempts the income itself. All foreign dividends, interest, and gains must still be reported on your tax return regardless of the cost amount.
Sources
- https://bbs.fcgvisa.com/t/t1135/54690
- https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/foreign-reporting/questions-answers-about-form-t1135.html
- https://www.mycostbase.ca/blog/t1135-foreign-property-reporting-canada/
- https://www.modernaxis.ca/blog/t1135-foreign-property-reporting