Short answer
Yes, if your specified foreign property cost more than CAD $100,000 in total at any time in the year: foreign accounts, stocks (including U.S. stocks in Canadian brokerages), foreign rentals, bonds. Personal-use property and RRSP/TFSA holdings are excluded.
What counts, what does not
Counted: funds in foreign accounts, shares of non-resident corporations (and foreign shares held in Canadian brokerage accounts), interests in non-resident trusts, foreign rental real estate, bonds and debts of non-residents, and crypto held on foreign platforms in many fact patterns.
Not counted: property inside RRSPs, RRIFs, TFSAs and other registered plans; personal-use property like a vacation home you do not rent; assets used exclusively in an active foreign business; and shares of foreign affiliates (those go on the T1134 instead).
The test is cost, not value — CAD $100,000 of aggregate cost at any moment in the year, even for a day.
The two reporting tiers
Between $100,000 and $250,000 of cost, the simplified method asks only for property types, top jurisdictions and totals. Above $250,000, the detailed method itemizes each property with its country, maximum cost in the year, year-end cost and income. Brokerage-level aggregation is allowed for accounts with country-by-country summaries.
Penalties and catch-up
Late filing costs $25 a day to $2,500 per year — with no tax owing required — and gross-negligence versions scale far higher. Multiple missed years are a Voluntary Disclosures Program candidate: penalty relief in exchange for coming forward before the CRA asks. Since the T1135 pairs with unreported foreign income in most cases, the disclosure should cover both at once.
Reviewed for the 2025 tax year by Udit Gupta, International Tax, Cross-Border Tax & Transfer Pricing Expert, Legal Quotient Consultants.
General information, not advice for your specific situation —
contact us on the 24-hour helpline to discuss your circumstances.
