Home › Articles › Canada · Taxes

Do my Alipay balance and A-share account count for T1135?

⚠️ Disclaimer: For general information only — not tax, financial, or legal advice. Figures may be outdated or incorrect; tax rules change frequently. Verify important decisions with the CRA/IRS or a qualified professional. You use this information at your own risk.
The short answer

Yes — take the conservative view and count both. A-share holdings are unambiguously foreign shares (specified foreign property). An Alipay or WeChat Pay balance is money held with a foreign institution; the CRA has not issued a specific ruling on e-wallets, but practitioners treat foreign e-wallet balances the same as foreign bank deposits, and both count toward the $100,000 threshold.

What counts as specified foreign property

Counts toward $100,000Does NOT count
Foreign bank accounts and depositsPersonal-use property (your foreign home, car)
Shares of foreign corporations (including A-shares)Property used in an active business
Foreign mutual funds, ETFs, bondsAssets inside RRSP, TFSA, RRIF, RESP
Debts owed by non-residentsShares of a foreign affiliate (>10% ownership)
Foreign real estate (not personal-use)Canadian property
Precious metals held abroad
Foreign e-wallet balances (conservative view)

The Alipay grey area

The Income Tax Act predates Alipay. No CRA folio says "e-wallets are foreign bank accounts." But the balance is a claim on a foreign financial institution, functionally identical to a deposit. Given the penalties for under-reporting, almost every cross-border accountant advises clients to include it. The cost of including it is zero; the cost of excluding it wrongly can be $2,500+.

A-shares are clear-cut

Shares listed in Shanghai or Shenzhen are shares of non-resident corporations — squarely within specified foreign property. Report the total cost (what you paid), not the market value.

Frequently asked questions

Does the $100,000 test use market value or cost?

Cost — what you paid. A portfolio now worth $200,000 that cost $80,000 does not trigger the filing requirement.

What about crypto on a foreign exchange?

CRA treats cryptocurrency as specified foreign property when held through a foreign platform. Include the cost.

My foreign pension — does it count?

Foreign pension plans are generally specified foreign property unless excluded as an interest in certain trusts. When in doubt, disclose.

Sources

  • https://aylcpa.ca/zh/post/2563
  • https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/foreign-reporting-requirements.html (CRA, specified foreign property)
Disclaimer — please read. This article is for general information and educational purposes only. It is not tax, accounting, legal, financial, or immigration advice, and reading it does not create a professional or client relationship between you and Llandora. Tax and immigration rules change frequently and differ by country, province/state, and personal circumstances; figures, thresholds, and examples in this article may be outdated, incomplete, or incorrect, and may not apply to your situation. Always verify current rules with the official sources (CRA, IRS, IRCC, USCIS) and consult a licensed professional before making any decision. Llandora makes no warranty of any kind — express or implied — about the accuracy, completeness, reliability, or timeliness of this content. To the fullest extent permitted by law, Llandora disclaims all liability for any loss, damage, cost, or expense arising from errors or omissions in this article or from any action taken or not taken in reliance on it, whether direct, indirect, incidental, or consequential. You rely on this article entirely at your own risk.