The checker above calculates your total specified foreign property cost basis in Canadian dollars and identifies whether Form T1135 reporting is mandatory, as well as whether you qualify for the Simplified Method (Part A) or must prepare Detailed Reporting (Part B).
The Canada Revenue Agency (CRA) requires every Canadian resident individual, corporation, or trust to file Form T1135 (Foreign Income Verification Statement) if the total cost amount of all specified foreign property exceeded $100,000 CAD at any point during the tax year — not just at December 31st.
Specified Foreign Property: What Counts vs. What Is Exempt
Determining whether you cross the threshold requires categorizing your non-registered investments correctly. Registered accounts and Canadian-domiciled funds are completely exempt.
| Asset Type | Counted on T1135? | CRA Classification & Guidance |
|---|---|---|
| U.S. Stocks (e.g. AAPL, MSFT, NVDA) | Yes | Category 2: Shares of non-resident corporations held in non-registered accounts. |
| U.S.-Listed ETFs (e.g. VTI, VOO, QQQ) | Yes | Category 4: Interests in non-resident trusts held in non-registered accounts. |
| Foreign Currency Cash / High-Interest Cash | Yes | Category 1: Funds held outside Canada or foreign currency bank/brokerage deposits. |
| Foreign Corporate or Government Bonds | Yes | Category 3: Indebtedness owed by non-resident persons. |
| Foreign Rental Real Estate | Yes | Category 5: Real property situated outside Canada (excludes personal-use vacation property). |
| Crypto Assets on Foreign Exchanges | Yes | Category 6: Intangible property situated outside Canada. |
| TSX-Listed Canadian ETFs (e.g. XUU, VXC, XEF) | No (Exempt) | Canadian mutual fund trusts; holding TSX units does not trigger T1135 filing. |
| Any Holdings in RRSP, TFSA, FHSA, RESP, RRIF | No (Exempt) | Registered plans are statutory exemptions under subsection 233.3(1) of the Income Tax Act. |
| Personal-Use Vacation Property | No (Exempt) | Foreign residential property used primarily (>50%) for personal enjoyment. |
Simplified vs. Detailed Reporting ($100k vs. $250k Tiers)
Form T1135 uses a two-tier compliance structure designed to reduce administrative overhead for smaller portfolios while requiring full transparency for larger holdings:
- Tier 1 — Under $100,000 CAD (No Filing Required): If the aggregate cost of all specified foreign property remained under $100,000 CAD on every single day of the year, you do not file Form T1135.
- Tier 2 — $100,000 to $249,999.99 CAD (Simplified Reporting - Part A): You check off the categories of foreign property held, enter the top 3 country codes by cost amount, and report total gross income received and total net capital gains/losses realized from foreign property.
- Tier 3 — $250,000 CAD or More (Detailed Reporting - Part B): You must report specific data for every category, including the country code, maximum cost amount during the year, year-end cost amount, gross income earned, and realized gain or loss.
Cost Amount vs. Fair Market Value: The Critical Distinction
A frequent trap for Canadian investors is checking their December brokerage statement’s market value. The T1135 threshold is determined strictly by adjusted cost base (cost amount in CAD), not market value:
- CAD conversion: Express each foreign asset’s cost amount in Canadian dollars using a documented rate applicable to its acquisition. CRA generally points to Bank of Canada daily rates and also recognizes qualifying alternatives.
- Market Declines Do Not Eliminate Filing: If you invested $115,000 CAD into U.S. equities and their market value drops to $70,000 CAD, you must still file Form T1135 because your cost amount is $115,000 CAD.
- Market Growth Alone Does Not Trigger Filing: If you bought U.S. shares for $80,000 CAD and their market value surged to $160,000 CAD without any new purchases, your cost amount remains $80,000 CAD, so no T1135 filing is required.
Intra-Year Rule: Crossing for Even One Day
The Income Tax Act specifies that the filing obligation is triggered if total foreign cost exceeded $100,000 CAD at any time during the year.
For example, if you held $90,000 CAD in U.S. stocks, deposited $20,000 CAD in USD cash in February to execute a trade, and withdrew the cash in April, your peak foreign cost was $110,000 CAD. You must file Form T1135 for that tax year, even if your year-end balance was under $100,000 CAD.
Worked Numerical Example: Multi-Asset Threshold Calculation
Consider an investor holding the following assets across non-registered accounts during the year:
| Asset | Currency Cost | BoC FX Rate | Cost in CAD | T1135 Category |
|---|---|---|---|---|
| 200 shares Microsoft (MSFT) | $70,000 USD | 1.3500 | $94,500 CAD | Category 2 (Foreign shares) |
| 100 shares Vanguard Total Stock (VTI) | $22,000 USD | 1.3600 | $29,920 CAD | Category 4 (Foreign trust) |
| U.S. Dollar Cash Balance | $12,000 USD | 1.3450 | $16,140 CAD | Category 1 (Funds outside Canada) |
| iShares Core S&P 500 TSX (XUS.TO) | $30,000 CAD | 1.0000 | $30,000 CAD | Exempt (TSX-listed Canadian ETF) |
Threshold Determination:
- Countable Foreign Property Total: $94,500 + $29,920 + $16,140 = $140,560 CAD.
- Exempt Property: $30,000 CAD in TSX-listed XUS is excluded.
- Filing Status: Because $140,560 CAD ≥ $100,000 CAD and < $250,000 CAD, the investor must file Form T1135 using Part A (Simplified Reporting Method).
CRA Penalties and Voluntary Disclosures
Failing to file Form T1135 carries strict statutory penalties under section 162(7) of the Income Tax Act:
- Late Filing Penalty: $25 per day, minimum $100, up to a maximum of $2,500 CAD per tax year, plus compound daily arrears interest.
- Gross Negligence / Failure to File: If failure is intentional or reckless, $500 per month up to 24 months ($12,000), or 5% of the maximum cost amount of foreign property.
- CRA Voluntary Disclosures Program (VDP): If you missed filing T1135 for prior years, you may apply under the CRA Voluntary Disclosures Program before the CRA contacts you to request relief from penalties and interest.
Scope note: The checker above provides threshold calculation and filing tier estimates based on user-entered cost amounts. For foreign exchange conversion of U.S.-dollar trades , pooled ACB calculation across brokerages, and audit-ready Schedule 3 reporting, see the USD Stocks Capital Gains Guide and Canadian Adjusted Cost Base Checklist .
Frequently asked questions: T1135 Foreign Property Threshold Tracker
What counts as specified foreign property for T1135 purposes?
Specified foreign property includes shares of foreign corporations (e.g. U.S. equities like AAPL or NVDA), units of foreign ETFs (e.g. VTI or SPY), foreign currency cash held in Canadian or foreign brokerage accounts, foreign debt or bonds, interests in foreign mutual funds or trusts, and foreign rental real estate. It excludes assets held inside registered accounts (RRSP, TFSA, FHSA, RESP) and Canadian-domiciled ETFs listed on the TSX.
Does the $100,000 threshold apply to fair market value or what I paid?
The threshold is strictly based on cost amount (what you paid converted to CAD at the transaction date exchange rate), not current market value. A portfolio purchased for $110,000 CAD that drops to $65,000 CAD in market value still triggers mandatory T1135 filing because the original cost amount exceeded $100,000 CAD.
Are Canadian-domiciled ETFs like XEF, VXC, or XUU included?
No. Canadian-domiciled ETFs listed on the Toronto Stock Exchange (TSX) are Canadian trust units, even when they invest entirely in foreign stocks. Holding TSX-listed ETFs does not count toward the $100,000 CAD threshold. However, holding U.S.-listed ETFs like SPY, VOO, or QQQ directly in a non-registered account does count as specified foreign property.
What is the difference between Simplified (Part A) and Detailed (Part B) reporting?
If your total foreign property cost was between $100,000 and $249,999.99 CAD at all times in the year, you qualify for the Simplified Reporting Method (Part A), which only requires checking property categories, listing your top 3 country codes, and reporting total gross foreign income and capital gains. If total foreign cost reached $250,000 CAD or more at any point, you must complete Part B Detailed Reporting with itemized tracking per category.
What are the CRA penalties for late or missed T1135 filing?
The standard penalty for failing to file Form T1135 on time is $25 per day, up to a maximum of $2,500 per tax year plus interest. If the failure is deemed gross negligence, penalties can reach $500 per month up to $12,000, or 5% of the highest cost amount of foreign property.