Form T1135: who has to file the Foreign Income Verification Statement

Form T1135 is not a tax calculation. It is an information return that tells the CRA what foreign assets you hold. Nothing is taxed on the form itself, which is exactly why it gets forgotten — and why the penalties for missing it are out of proportion to the effort of filing it.

Who has to file

A Canadian resident individual, corporation, or trust, and most partnerships, must file Form T1135 for a year in which the total cost amount of their specified foreign property exceeded $100,000 at any time in the year. A corporation with a U.S. brokerage account, an owner holding shares of a foreign private company, or a business with rental property abroad can all fall inside it.

The $100,000 test is about cost, not value

The threshold is based on the cost amount, which is defined in the Income Tax Act and generally means adjusted cost base rather than fair market value. That cuts both ways: a portfolio that has grown well past $100,000 in value may still sit under the threshold on cost, and a property bought for more than $100,000 that has since fallen in value is still reportable.

Two further points that catch people out:

• The threshold is the total across all specified foreign property. Shares with a cost of $75,000 plus a foreign bank balance of $35,000 totals $110,000 and triggers the filing, even though neither holding exceeds $100,000 on its own.
• The test applies at any time in the year. If you crossed $100,000 in March and sold everything in August, you still have to file and still have to report all specified foreign property held during the year.

Simplified versus detailed reporting

The form has a two-tier structure:

• Part A — simplified method. Available if the total cost of specified foreign property stayed under $250,000 throughout the year. You tick a box for each type of property held rather than listing each holding.
• Part B — detailed method. Required if the total cost reached $250,000 or more at any time in the year, and available by choice at any level.

You complete one or the other, never both. Where property is held with a Canadian registered securities dealer or a Canadian trust company, the aggregate amount can be reported on a country-by-country basis in the category built for that purpose, which is far less work than listing every security.

When it is due

Form T1135 must be filed on or before the due date of the taxpayer’s income tax return — or, for a partnership, the due date of the partnership information return — even if the return itself is not required to be filed. For a corporation, that means the same deadline as the T2, so it belongs on the same checklist as your T2 filing deadline. Corporations can file the form electronically through EFILE.

The penalties

These are the numbers that make the form worth taking seriously:

• Failure to file: $25 per day for up to 100 days, with a minimum of $100 and a maximum of $2,500.
• Knowingly, or through gross negligence: $500 per month for up to 24 months, to a maximum of $12,000, less any penalties already levied.
• Failure to comply with a formal demand to file: $1,000 per month for up to 24 months, to a maximum of $24,000.
• After 24 months: an additional penalty of 5% of the cost of the foreign property, less penalties already levied.
• False statement or omission: the greater of $24,000 or 5% of the cost of the foreign property.

There is a second consequence that is easy to miss. For 2013 and later tax years, the CRA’s normal reassessment period is extended by three years where the taxpayer failed to report income from a specified foreign property and the T1135 was not filed, was filed late, or was filed inaccurately. That keeps the year open long after it would otherwise have closed — which is worth reading alongside the record retention rules.

If you have missed a year

Relief from these penalties may be granted under the taxpayer relief provisions on written request, and the Voluntary Disclosures Program may be available where a valid disclosure is made before the CRA contacts you. Both routes are far better than waiting. Our guide to the Voluntary Disclosures Program covers what a valid disclosure requires.

The bottom line

T1135 costs almost nothing to file and a great deal to skip. If your corporation or your household holds foreign investments, foreign bank accounts or foreign real estate held to earn income, run the cost-amount total once a year. If it clears $100,000 at any point, the form is due with the return.

This article is general information for Canadian business owners and is current as of July 2026. It is not tax, legal or accounting advice, and it does not create a client relationship. Tax rules change and your situation is unique — please speak with a CPA before acting on anything here.