T1135 Foreign Income Verification Statement: a Canadian's CAD 100,000 trigger on US assets

Section 01Section 1. Why T1135 exists in your life as a Canadian with Florida assets

The CRA introduced T1135 in 1999 to close an information gap. Canadian residents are taxed on worldwide income, but until T1135, the CRA had no systematic mechanism to know which Canadian taxpayers held substantial foreign assets generating reportable income. The form is the bridge between the worldwide-income tax obligation and the CRA's audit capability.

For a Canadian who buys property in Florida, holds a US brokerage account, or accumulates US-dollar cash above CAD 100,000-equivalent in a US bank, T1135 is the disclosure that tells the CRA: this is the asset, this is its cost, this is its country, this is its income.

Three triggers activate T1135 for a typical Florida-connected Canadian:

A Florida condo purchased in personal name with a cost above CAD 100,000.

A US brokerage account at Schwab, Fidelity, Interactive Brokers US, ETrade, or any US-domiciled broker, where the cost amount of the holdings exceeds CAD 100,000.

A US-resident corporation in which the Canadian holds shares (operating company, holding company, real-estate-holding LLC), where the share cost exceeds CAD 100,000.

A snowbird who keeps Canadian residency, owns no Florida property, and uses a Canadian credit card for US purchases has no T1135 filing if the small US cash float in a US chequing account stays under threshold. A snowbird who buys a Florida condo above CAD 100,000-equivalent files T1135 for as long as they own it.

Section 02Section 2. Who must file: Canadian residency and the entity rules

The T1135 obligation attaches to Canadian residents. The "resident" definition follows the common-law residency rules and the deemed-residency rules at ITA § 250. A Canadian who emigrates to Florida and severs Canadian residency files T1135 for the year of departure (covering the period as a resident) and stops filing for subsequent non-resident years.

A Canadian who is dual-resident under treaty (Canadian-resident under domestic law but treated as US-resident under the treaty tie-breaker for treaty purposes only) is generally still required to file T1135 because the form is rooted in domestic Canadian residency, not treaty residency. Cross-border CPAs sometimes argue otherwise; conservative practice is to file.

A Canadian individual who holds foreign property as nominee for someone else does not file T1135 (the beneficial owner does).

A Canadian-controlled private corporation files T1135 if its specified foreign property exceeds the threshold. Each individual shareholder also files for their own personally-held SFP, separately.

A Canadian partnership where all members are Canadian residents files T1135 at the partnership level if the partnership's SFP exceeds threshold; the partners do NOT separately report the same property.

A trust that is resident in Canada files T1135 if the trust's SFP exceeds threshold. Beneficiaries do not separately report unless they themselves hold the underlying property.

A Canadian who holds a Florida condo jointly with a US-resident family member (a parent who lives in Florida year-round, an adult child who emigrated): the Canadian reports their proportional share of the cost on T1135. The US-resident co-owner has no T1135 obligation (they are not a Canadian resident).

Section 03Section 3. Specified foreign property: what counts and what does not

The ITA § 233.3 definition is broad. Specified foreign property includes:

Funds in or vested in any foreign bank or other foreign deposit-taking institution. A US chequing account at Bank of America, BMO Harris, RBC Bank US, TD Bank US, Wells Fargo, Chase, Fifth Third, Citi, etc.

Shares of any non-resident corporation. US-listed common shares (Apple, Microsoft, Alphabet, Tesla) held in a US brokerage account. The same shares held in a CANADIAN brokerage account are STILL reportable, because the issuer is foreign even though the custodian is Canadian.

Indebtedness owed by a non-resident person. A loan to a US-resident family member, a US-issued bond, a debt instrument from a US issuer.

Interests in any non-resident trust. A Florida revocable living trust where the Canadian is grantor or beneficiary.

Real property situated outside Canada (other than personal-use property). A Florida condo, vacation home, rental house, raw land, commercial property. PERSONAL-USE PROPERTY is excluded — but the personal-use exclusion is narrow: a property that is rented out for any meaningful period is not personal-use.

Any other tangible property situated outside Canada that is used in a business. A US-located trade fixture, equipment, inventory.

Property held by a non-resident agent on behalf of the Canadian.

What does NOT count (the carve-outs in ITA § 233.3(1) "specified foreign property" definition):

Property held in a Canadian registered account: RRSP, RRIF, TFSA, FHSA, RESP, RDSP, LIRA, LIF, RPP, IPP. US securities held in your Canadian RRSP are NOT reportable.

Personal-use property situated outside Canada. A Florida condo held strictly for personal use, with no rental income, no time-share arrangement, may qualify — but the bar is high and the CRA narrows the exception.

A foreign-currency credit-card balance (it's a debt OWED, not property held).

A US-incorporated corporation actively carrying on business outside Canada: only the SHARES of that corporation are SFP for the Canadian shareholder; the corporation's own assets are not.

The cost amount used on T1135 is the adjusted cost base (ACB) for capital property, the principal amount for debt, the original investment for partnership interests. Cost is in Canadian dollars; foreign-currency costs are converted at the rate on the date of acquisition (not the year-end rate).

Section 04Section 4. The two reporting tiers: simplified vs detailed

T1135 has two reporting paths based on the maximum cost during the year:

Simplified reporting (cost between CAD 100,000 and CAD 250,000): you check boxes for each category of specified foreign property held during the year, indicate the highest country exposure, and report aggregate income. No institution-level disclosure.

Detailed reporting (cost above CAD 250,000): you list, for each category, every institution or asset, with the country, the maximum cost amount during the year, the cost amount at year end, the income earned (gain or loss for capital property), and the gain or loss on disposition. The form has separate tables for:

• Funds held outside Canada
• Shares of non-resident corporations
• Indebtedness owed by non-residents
• Interests in non-resident trusts
• Real property outside Canada
• Other property outside Canada
• Property held in foreign accounts maintained at non-resident financial institutions

A Canadian with a USD 200,000 Florida condo (CAD 272,000 at year-end FX of 1.36), no other foreign property, files detailed reporting. The condo gets one line in the real-property table: country US, max cost CAD 272,000, year-end cost CAD 272,000, income CAD 0 (if no rental), gain CAD 0 (no disposition).

A Canadian with a USD 80,000 Schwab brokerage account (CAD 109,000) and a USD 90,000 Florida condo (CAD 122,000) crosses the CAD 100,000 threshold but stays under CAD 250,000. Simplified reporting.

A Canadian with the same Schwab account but additionally a USD 250,000 condo would file detailed because aggregate cost exceeds CAD 250,000.

The simplified vs detailed line is determined by the AGGREGATE maximum cost, not by category.

Section 05Section 5. The Florida condo case: the most common Canadian situation

A Quebec couple buys a 2-bedroom condo in Hollywood, Florida, for USD 285,000 in March 2026. The exchange rate on the day of the purchase is USD/CAD 1.36, so the Canadian cost amount is CAD 387,600. Each spouse holds 50 percent.

Each spouse files Form T1135 individually for 2026 (and every subsequent year of ownership): each reports CAD 193,800 (50 percent of 387,600) in real property in the United States. The aggregate per spouse is below CAD 250,000, so each could file simplified — but each needs to look at their TOTAL specified foreign property (this condo plus any US brokerage, US bank balances). If either has additional US assets pushing aggregate above CAD 250,000, that spouse files detailed.

Year-by-year impact:

If the condo is purely personal-use (snowbird use only, never rented), some Canadian tax practitioners argue it falls under the personal-use exclusion. CRA's position has tightened over the years; the conservative practice (and the practice we recommend) is to report.

If the condo is rented out for any portion of the year (even one weekly rental during a snowbird gap), the personal-use exclusion is lost. Reportable on T1135. The rental income is also reportable on the T1 (with foreign tax credit relief for US tax already paid on Form 1040-NR or Form 1040-NR Schedule E).

If the couple later sells the condo (FIRPTA withholding 15 percent, US capital gains tax, etc., covered in our dedicated guide on FIRPTA and on Canadian capital gains 50 percent inclusion), the disposition is reported on the final T1135 for the year of sale, and the capital gain is reported on the T1 Schedule 3.

If the couple severs Canadian residency and emigrates permanently, the year of departure has a deemed disposition (departure tax under ITA § 128.1) of all foreign property NOT specifically excluded; the condo would be a deemed-disposition asset, the condo's value at the date of departure becomes the new ACB for US purposes, and T1135 is filed one final time for the year of departure, then never again.

Section 06Section 6. Comparison: T1135 (CRA) vs Form 8938 (IRS) vs FBAR (FinCEN)

Two cross-border situations are common:

A Canadian snowbird with Florida condo + Canadian residency: T1135 yes, Form 8938 no (not US person), FBAR no.

A Canadian-citizen, US-tax-resident permanent emigrant who keeps a Quebec cottage and Canadian RRSP after moving: T1135 not applicable (non-resident), Form 8938 yes (US person, abroad threshold USD 200K single), FBAR yes if Canadian accounts > USD 10K.

A green-card-holder who lives in Quebec full-time: T1135 yes (Canadian resident), Form 8938 yes (US person, abroad threshold), FBAR yes. Both regimes apply.

Section 07Section 7. The 24-month statute extension: why missing T1135 is asymmetrically dangerous

Under ITA § 152(4)(b.2), if a Canadian taxpayer was required to file T1135 but did not, or filed an incomplete T1135, the normal three-year reassessment period (or four years for non-arms-length transactions) is extended by an additional three years for any income, gain, or loss attributable to the unreported foreign property.

In practice: a Canadian who failed to file T1135 in 2020 for a Florida condo may have any 2020 reassessment exposure extending to 2026, then to 2029 if the missing T1135 covered transactions in 2023, etc. The longer the gap, the longer the CRA's window to assess additional tax.

Combined with the CAD 25/day basic penalty (cap CAD 2,500 per year) and the heavier gross-negligence penalties, the practical exposure of a missed T1135 over a 5-year holding period of a Florida condo can exceed CAD 12,500 in penalties plus extended reassessment exposure.

The Voluntary Disclosures Program (VDP), administered by the CRA, provides a structured path for Canadians who missed T1135 to come forward. Acceptance into the VDP is discretionary and requires the disclosure to be voluntary (before the CRA contacts the taxpayer about the matter), complete (all unreported foreign property disclosed), with payment (or acceptable security for payment) of estimated tax liability, and a 12-month minimum gap for "general" track or no minimum for "limited" track (which carries reduced penalty waiver).

Section 08Section 8. Worked example: a BC retiree's snowbird real estate plus brokerage

A 67-year-old retiree from Kelowna, BC, owns:

A Florida snowbird condo in Cape Coral, purchased in 2024 for USD 210,000 (CAD cost CAD 285,600 at then-FX 1.36). Held in personal name, used personally three months a year, never rented.

A US brokerage account at Charles Schwab opened in 2024 for portfolio diversification: USD 145,000 in US-listed ETFs (cost CAD 197,200).

A small US-dollar chequing account at TD Bank US for snowbird bills: max balance during 2026 USD 6,500 (CAD 8,840).

His RRSP at RBC contains USD 90,000 of US-listed shares: NOT reportable on T1135 (registered plan exclusion).

His TFSA at Wealthsimple contains USD 35,000 of US-listed ETFs: NOT reportable on T1135 (TFSA exclusion).

T1135 obligation: aggregate SFP cost for 2026:

• Florida condo: CAD 285,600
• Schwab brokerage: CAD 197,200
• TD Bank US chequing: CAD 8,840
• Total: CAD 491,640

This exceeds CAD 250,000, so DETAILED reporting is required. He files T1135 listing:

Real property (US): Florida condo at CAD 285,600 max cost, CAD 285,600 year-end cost, CAD 0 income, CAD 0 gain.

Funds outside Canada (US): TD Bank US chequing at CAD 8,840 max, CAD 7,200 year-end (assume he spent some), CAD 0 income (US chequing pays no interest in his case), CAD 0 gain.

Shares of non-resident corporations (US): held through Schwab; he can report at the institution-aggregate level (most common practice) listing Schwab as the institution, US country, CAD 197,200 max cost, year-end cost based on actual holdings, dividend income converted to CAD, capital gains/losses on dispositions during the year. Detailed share-by-share reporting is not required when held in a custodial account.

If his condo were also rented, he would add US rental income to T1, claim FTC on Form T2209 for US tax paid, and continue T1135 reporting.

If he failed to file T1135 for 2026 entirely, exposure: CAD 25/day basic from May 1, 2027 onwards = CAD 2,500 cap. If CRA later determines gross negligence, CAD 12,000 to 24,000. If false statements, 5 percent of CAD 491,640 = CAD 24,582 additional penalty. Plus 24-month extension of reassessment period.

Section 09Section 9. Common mistakes Canadians make on T1135

Forgetting US securities held in a Canadian brokerage account. The custodian is irrelevant; the issuer's residence is what matters. US-listed shares held at TD Direct Investing are SFP because Apple, Microsoft, etc. are non-resident corporations.

Reporting personal-use Florida condo as exempt. The CRA personal-use exclusion is narrow. Conservative practice: report all foreign real estate above the threshold.

Using market value instead of cost amount. T1135 uses ACB (cost), not FMV. Detailed reporting also requires the maximum cost during the year.

Reporting a US-corporation-owned Florida condo as real estate. If the condo is held by a US LLC, the Canadian holds shares in a non-resident corporation, not real estate directly. The shares are SFP; the underlying condo is not separately reportable.

Forgetting to file when no income was earned. T1135 is information-only; income is irrelevant to the filing requirement. A vacant Florida condo with no rental income still triggers T1135.

Confusing simplified and detailed thresholds. Simplified is for cost between CAD 100,000 and CAD 250,000. Above CAD 250,000 requires detailed.

Not filing in the year of purchase. T1135 is required for the YEAR in which SFP cost first exceeds CAD 100,000, even if the property was acquired late in the year.

Not filing in the year of sale. T1135 is required for the year of disposition with the gain/loss reported, even if the property is gone by year end.

Filing T1135 alone without filing the T1 return that contains it. T1135 is a schedule attached to T1; it cannot be filed in isolation.

Skipping T1135 because "the CRA already gets FATCA data." FATCA data flows from Canada to the US, not the other way. The CRA does not receive automatic data on Canadian-resident holdings of US property; T1135 is what tells them.

Section 10Section 10. Action checklist for a Canadian with US assets

1. Inventory every US-situs asset and every account at a foreign institution: real estate, brokerage, bank, partnership interest, corporate share, debt instrument, trust interest.
2. For each, determine the cost amount in Canadian dollars (acquisition cost converted at the rate on the date of acquisition).
3. Sum the cost amounts. If the aggregate exceeds CAD 100,000 at any point during the year, T1135 is required for that year.
4. Determine simplified vs detailed: under CAD 250,000 simplified, above detailed.
5. Gather, for detailed reporting: institution name and country for each asset, max cost during the year, year-end cost, income earned, capital gains or losses on dispositions.
6. Complete Form T1135 (paper or via your tax preparer's software).
7. File with your T1 return (April 30, June 15 self-employed).
8. Retain all supporting documents (purchase contracts, brokerage statements, exchange-rate records) for at least seven years.
9. If you missed T1135 for prior years, consult a Canadian tax professional about the Voluntary Disclosures Program BEFORE the CRA contacts you about the issue.
10. Re-evaluate annually: every year of continued ownership requires a new T1135 if the threshold remains crossed.

Section 11Section 11. What this guide does not cover

The departure tax under ITA § 128.1 (deemed disposition on emigration) which interacts with T1135 in the year of severance.

The detailed mechanics of the foreign tax credit (covered in our dedicated guide on FTC for Canadian US-asset holders).

US tax obligations on the same property (FIRPTA, US capital gains, US estate tax for non-resident aliens) covered in our chapter 04 sale and chapter 05 succession guides.

The treatment of a US-resident corporation owned by a Canadian (CFC analysis on the Canadian side; controlled foreign affiliate rules under ITA § 91-95).

The interaction of T1135 with Form NR4 information slips issued to the Canadian by US payers.

Section 12Section 12. FAQ

Do I need to file T1135 if my US assets had no income this year? Yes. T1135 is information-only; income is irrelevant. The trigger is cost amount above threshold, regardless of income.

My Florida condo is held jointly with my spouse. Do we file one T1135 or two? Two. Each spouse reports their proportional share of the cost on their own T1135.

My US securities are inside my RRSP. Do they count? No. Specified foreign property explicitly excludes property held in registered accounts (RRSP, TFSA, RESP, RRIF, FHSA, RDSP, LIRA, LIF).

What exchange rate do I use? Cost amount uses the rate on the date of acquisition. Year-end values for detailed reporting may use the year-end rate or the average rate; CRA accepts either consistently applied. Most practitioners use the Bank of Canada year-end rate.

Is the personal-use exclusion safe for my snowbird condo? Conservative practice is to file. The CRA's interpretation of personal-use has tightened. If the condo is ever rented out (even a single short-term rental), the exclusion is lost. Filing a T1135 every year is much safer than missing one and being hit with extended reassessment plus penalty.

My Florida condo cost is just under CAD 100,000. Do I file? Test the threshold at maximum cost during the year, in CAD, including all your other foreign property. If the AGGREGATE max cost exceeded CAD 100,000 at any time, you file. If your condo alone was CAD 99,000 and you also have a USD 5,000 US chequing account, your aggregate is over.

What's the deadline? Same as your T1: April 30, or June 15 if you or your spouse is self-employed. Late T1135 attracts penalty even if the underlying T1 is on time.

Do I file T1135 in the year I sell the property? Yes. Report the disposition; the property goes off the next year's filing.

I'm a snowbird who became a US person mid-year. Do I file T1135 as a Canadian and Form 8938 as an American? If you remain a Canadian resident under domestic Canadian law for the whole year, file T1135. If you also became a US person under SPT or green card during the year, you may file Form 8938 with your dual-status 1040 for the US-resident portion. Cross-border CPA strongly recommended for the year of transition.

The CRA already got FATCA data from US institutions. Do I still need to file? FATCA data flows the OTHER way (Canadian financial institutions report US-person accounts to CRA, who passes to IRS). The CRA does not automatically receive data from US institutions on Canadian-residents. T1135 is your disclosure to the CRA.

Where can I find Form T1135? Available on the CRA website at https://www.canada.ca/en/revenue-agency/services/forms-publications/forms/t1135.html. Most tax-preparation software (TurboTax, UFile, Wealthsimple Tax, H&R Block) generates T1135 automatically when foreign-property questions are answered yes.