Reporting crypto on T1135 — what should I check first?

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Answer

The analysis asks whether the holding is specified foreign property and whether it is held with a foreign custodian. One question decides whether this is a filing or a project.

What to check first

The analysis asks whether the holding is specified foreign property and whether it is held with a foreign custodian. Records of cost in Canadian dollars at acquisition are what make the report possible at all.

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When the rule breaks

Canadian foreign-property reporting can reach crypto held with a foreign platform, measured on cost, and the report is due whether or not anything was disposed of.

Reporting crypto on T1135 — what should I check first?
ItemAmount
Cost of the propertyC$284,000
Value on the departure dayC$542,440
Accrued gain treated as realisedC$258,440
Amount assumed to enter incomeC$129,220
Tax at an assumed 35%C$45,227

C$45,227 becomes payable in a year with no sale and no cash. That is what makes the departure date a planning variable: losses realised before it, an election to defer payment against security, and defensible valuations for anything private all change this number.

The figures here are an illustration, not an engagement: amounts are picked so the mechanism is easy to follow, and every rate or threshold is an assumption of the example. Before anything is filed for you, each one is confirmed with the issuing authority for your own tax year.

Where to go from here

The full treatment — who it binds, the deadline, the penalty and the fixed fee — is on Reporting crypto on T1135. Describe the situation in your own words; translating it into forms is our job.

Reviewed for accuracy for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. This is general information rather than advice about your file — a short call is the way to get the second.

International tax reporting, in practice

This is the page to read on international tax reporting. It takes reporting crypto on T1135 in order — the test that decides who is affected, the returns and forms that follow from it, and a fee quoted in writing before anything starts.

Cross-border situations we are engaged for

Case study 1

Rebuilding acquisition cost in Canadian dollars from exchange exports

The client's holdings had been accumulated over several years across two platforms, with coin-for-coin trades throughout and no cost record in Canadian dollars at all. We took the raw exports, ordered every acquisition by date, traced each coin-for-coin trade back to the lot it came from, and converted each acquisition using the rate for its own date from a single stated source. The engagement produced a cost schedule by lot, the working papers behind it, and a reporting position for each year, with the schedule built so the client can extend it rather than repeat the exercise.

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Case study 2

Deciding whether a self-custodied wallet belonged on the form

Most of the client's coins sat with a foreign platform and a substantial part had been moved into a wallet the client controlled alone. The two limbs of the test pulled in different directions for the wallet, and earlier filings had simply included everything without saying why. We worked the custodian question and the property question separately for each group of coins, took a position, and set out the alternative reading and why it was not preferred. The client received a written analysis, a corrected presentation for the years affected, and a rule to apply going forward.

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Case study 3

A first filing prepared for a year with no disposals

Nothing had been sold, no income arose, and the return as prepared gave no hint that a foreign-property question existed. The holding had been bought and left on a platform outside Canada. We established the acquisition dates and cost by lot, confirmed the contracting entity behind the platform account, and tested the reporting position for each year of ownership. The engagement produced the report for the years it was due, working papers supporting every figure, and a note explaining why a year without a single transaction had still carried an obligation.

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Case study 4

Splitting one account into reportable and excluded holdings

A single platform account held tokens, a stablecoin balance, a currency balance awaiting withdrawal and a position taken through a product the platform offered in its own name. Treating the account as one line would have stated the reporting position for none of it. We characterised each component, applied the specified foreign property test to each, and produced a schedule showing which parts entered the report, which did not, and the reason recorded against each. The account is now reported line by line, and the schedule carries forward each year.

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Case study 5

Bringing late years up to date with a documented position

The client had held coins on a foreign platform for several years without considering the foreign-property question, and came to us after reading about it. We established the cost by lot for every year, tested the position for each, and prepared the outstanding reports as a set rather than one at a time, so the figures tie across years. Where the treatment of a holding was genuinely open we recorded the position taken and the basis for it. The engagement produced the filings, a consolidated cost schedule and a memorandum for the file.

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Case study 6

Designing cost tracking before the next filing year began

This client arrived without a problem to fix. Holdings were growing, trades were frequent, and the cost record existed only as exchange exports nobody had ever put in order. We set up a lot-by-lot cost register in Canadian dollars with a single stated rate source, a routine for pulling exports before they age out of the platform, and a standing split between coins held with a platform and coins held under the client's own keys. The engagement produced that register populated to date and a written procedure, so each year starts from records rather than reconstruction.

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Case study 7

A Family Trust Abroad With Reporting on Both Sides

A trust settled in one country and a beneficiary living in another produces reporting for the trust, the settlor and the beneficiary, on different forms and different dates. The engagement maps who files what before anything is prepared.

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Case study 8

Accounts Reported Late When the Income Already Was

Where the income was on the return and only the account report was missed, a narrow route allows late filing with a reason attached. It is open only while no income is unreported and no examination has begun, which is why it is checked first.

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All case studies — every published engagement in one place.

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The deduction is taken on the sale price, not the gain — which is why an NRI property sale strands cash unless the certificate is applied for before closing.

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What people ask us about Reporting crypto on T1135

Does crypto go on a T1135?

It can. Canadian foreign-property reporting reaches property held with a foreign platform, so a balance on an exchange outside Canada is squarely inside the question rather than outside it. Two tests decide it: whether the holding is specified foreign property, and whether it is held with a foreign custodian. Neither test asks whether you sold anything. Answer them holding by holding rather than account by account, because one platform account can contain items that fall on different sides, and a single answer applied to the whole account states the position for none of it.

Is T1135 based on cost or on market value?

Cost is what drives it. The reporting question is built around the cost amount of specified foreign property rather than what the property is worth today, which surprises people whose crypto has multiplied in value and who expect the market figure to matter. The practical consequence is that the records you need are historic: what you paid, in Canadian dollars, on the date each lot was acquired. A screenshot of today's balance answers none of it. Market value still has its place on the form, so both sets of records earn their keep, but cost is what the reporting question turns on.

What if I never recorded the Canadian dollar cost?

Then the first piece of work is reconstruction, and it is usually possible. Exchange exports carry the date, the quantity and the price paid in whatever currency the trade settled, and the Canadian dollar cost follows by applying the rate for that date. Coins bought with other coins need the earlier lot traced back as well, which is where the chains get long. Do it once, properly, and the result is a cost schedule you carry forward for every future year. Record the method and the rate source alongside it, because the schedule is only as defensible as its working papers.

Do I file T1135 if I did not sell anything?

Disposals are not what triggers it. The report is due on the strength of what you held during the year, so a year in which you neither bought nor sold can still be a reporting year, and there may be no income entry on the return itself to prompt the thought. This is the most common way the form is missed. Test the position for every year the holding existed rather than only the years with transactions, and keep the year-end holding record even when nothing happened, because a quiet year still has to be evidenced if it is ever asked about.

Does crypto in my own wallet go on T1135?

That is a different question from a balance sitting with a platform, and the two can be answered differently. The custodian limb of the test looks for property held with a foreign custodian, and self-custody has no custodian at all: no account, no institution, no terms. Whether the holding is nonetheless specified foreign property has to be worked through on its own footing. What matters practically is that you can tell the two apart after the fact, so keep the record of which coins sat under your own keys and which sat with a platform, year by year.

Which exchange statements support a T1135 crypto entry?

Start with a complete trade export covering every year of ownership, because the cost side of the report is historic and cannot be rebuilt from a current balance. Add year-end statements, the deposit and withdrawal history with addresses, and the account terms naming the entity you contracted with. Keep the rate source used to convert each acquisition into Canadian dollars. Held together with the working papers, that set lets you show how every figure was derived. Pull the exports while the account is still open, because platforms close and historic statements go with them.

What is the penalty for a late T1135 or a missed FBAR?

Both are penalty regimes attached to the form rather than to any tax, which is why people who owed nothing still face them. The Canadian foreign property statement carries a per-month penalty with much larger amounts for a failure that continues or is made knowingly; the US account report is separate again and pivots on whether the failure was wilful. Relief exists — voluntary disclosure, reasonable cause, taxpayer relief — and it narrows once the authority makes contact. The reporting trigger on the US side is an aggregate balance over $10,000 at any point in the year. See late T1135 penalty relief.

Do I have to declare my dual citizenship?

A tax return does not generally ask you to declare which passports you hold; it asks about residence, and in the US case it applies to citizens by definition. What does ask is your bank. Account-opening self-certification under FATCA and the Common Reporting Standard asks which countries you are a tax resident or citizen of, and the answer is reported onward to the tax authority. So the practical answer is that the information arrives either way. See FATCA reporting.

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