T1135 Foreign Property Reporting in Canada (2026): When You Must File

The T1135 is one of the most-missed Canadian tax forms — especially among newcomers who still own property or accounts in their country of origin. Missing it is expensive: minimum $100 penalty, up to $2,500 for late filing, and CRA doesn’t accept “I didn’t know.” Here’s exactly when and how you have to file.

The trigger: $100,000 CAD threshold

If at ANY point during the tax year, your “specified foreign property” had a total cost basis (not market value) exceeding $100,000 CAD, you must file Form T1135 with your regular tax return.

Important: $100K is COST basis — what you paid in CAD when you bought it. If you bought a Vietnam apartment in 2010 for $80,000 and it’s worth $400,000 now, you’re BELOW the threshold (because cost is what counts). But if you bought another for $30K, total cost is $110K — over the line.

What counts as “specified foreign property”

• Foreign real estate (your old apartment in Saigon, Manila, Mumbai, Hong Kong, etc.)
• Foreign bank accounts — chequing, savings, GIC equivalents
• Foreign stocks, bonds, mutual funds held in a NON-Canadian brokerage
• Foreign currency held in cash (rare to trip the threshold alone)
• Shares in non-resident corporations (including your own foreign business)
• Interests in non-resident trusts
• Loans receivable from non-residents
• US-listed ETFs held in a Canadian non-registered brokerage account (US-listed = foreign property even via Canadian broker)

What does NOT count

• Foreign property in RRSP, RRIF, TFSA, FHSA, or RPP — registered accounts are exempt from T1135 entirely
• Personal-use property — your Florida vacation home (used only by family, not rented) doesn’t trigger T1135. If you rent it out, it does.
• Foreign property used in active business — not investment property
• Canadian mutual funds/ETFs that internally hold foreign stocks — VFV (CAD-denominated, listed on TSX) does NOT trigger T1135 even though it tracks US S&P 500