Do my Alipay balance and A-share account count for T1135?
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 $100,000 | Does NOT count |
|---|---|
| Foreign bank accounts and deposits | Personal-use property (your foreign home, car) |
| Shares of foreign corporations (including A-shares) | Property used in an active business |
| Foreign mutual funds, ETFs, bonds | Assets inside RRSP, TFSA, RRIF, RESP |
| Debts owed by non-residents | Shares 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)