T1135 vs T1134

One reports foreign property; the other reports foreign affiliates. A single foreign company can put you inside both, on different measures.

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The difference in one line

One reports foreign property; the other reports foreign affiliates. A single foreign company can put you inside both, on different measures.

Side by side

T1135 vs T1134
 T1135T1134
What is reportedSpecified foreign propertyForeign affiliates and their financial results
MeasureCost amount, in aggregateOwnership level, per affiliate
Who filesIndividuals, corporations, trusts, partnershipsThe same, where the affiliate test is met
Work involvedAssembling costs in Canadian dollarsRestating each affiliate's accounts on the required basis
PenaltyPer year, independent of taxPer year and per affiliate, independent of tax
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Which one applies to you

Test the property statement on cost across everything you hold, then test the affiliate return on your ownership of any foreign corporation. A founder who kept a company abroad usually owes both and discovers the second one late.

Where to go from here

If that describes your position, the next step is a short call — not a form.

Reviewed against current guidance for the 2025 and 2026 filing seasons by Udit Gupta, Cross-Border Tax Expert, Legal Quotient Consultants. Written as general guidance, not as a recommendation for your situation. Talk it through with us before acting on it.

International tax accountant — what this page covers

Read this page for international tax accountant. It works through T1135 vs T1134 from the beginning — whether it applies to you at all, what has to be filed if it does, and what the engagement costs, priced up front.

What working with us on T1135 vs T1134 looks like

Late and missed years are ordinary work

An unfiled history is not a reason to wait longer. We assess what is still open and what relief the delay attracts before the first return goes in.

Residence is tested, not assumed

Where you are resident for treaty purposes is a question with a method. We work through it and write down the answer, with the facts it rests on.

The reporting penalties get named early

The heaviest exposure on a cross-border file is usually a disclosure form, not the tax. We identify which ones apply before a deadline turns into a penalty.

Every figure on a page is traceable

Where a rate or a threshold appears in our writing it names the tax year it belongs to. Where it could not be confirmed, the page describes the mechanism and quotes no number.

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Cross-border tax case studies

Case study 1

Founder who kept an operating company abroad after emigrating

The client moved to Canada and left the operating company in the country of origin, filing personal returns here for several years without either foreign reporting return. We mapped the shareholding from the incorporation documents forward, established the cost amount of the shares in Canadian dollars, and tested the affiliate question separately on the ownership level. The engagement produced a filed set of property statements and affiliate returns for the open years, with a working paper recording how each cost figure was derived and which ownership test was met in which year.

Case study 2

Property statements filed for years while the affiliate return was missed

A long-standing filer had reported foreign property correctly but had never looked at the affiliate question, because the adviser who prepared the statements treated the shares as one more line of property. The review started from the corporate register rather than the investment reporting. We restated the foreign company's accounts on the required basis and prepared the outstanding affiliate returns alongside the statements already filed, so the two sets agreed on the same holding. The engagement produced a matched filing history and a note explaining the difference in measure to the client.

Case study 3

Canadian corporation reporting a wholly owned foreign subsidiary

A Canadian company had acquired a subsidiary abroad and continued to consolidate it for accounting purposes only. The reporting question was different: the affiliate return needs each affiliate's results restated on the basis the return requires, not the group's accounting presentation. We rebuilt the subsidiary's figures from its own statutory accounts, documented the currency treatment, and filed the affiliate return for the year of acquisition and each year since. The engagement produced a repeatable working file, so the following year's return starts from a schedule rather than a reconstruction.

Case study 4

Rebuilding cost amounts for an inherited foreign portfolio

An inherited portfolio held abroad had been reported inconsistently because nobody could establish what the holdings had cost. The property statement runs on cost amount in Canadian dollars, so the work was documentary rather than analytical. We traced the estate records, fixed the acquisition point for each holding, converted each figure, and set out the basis used where the record was incomplete. The engagement produced a filed statement supported by a schedule showing the source for every cost included, which is what makes the position defensible if the record is ever questioned.

Case study 5

Family trust holding a foreign interest that nobody had tested

The individual beneficiaries had been filing their own foreign property statements while the interest itself sat inside a family trust. The obligation belonged to the trust. We established which entity held what on each relevant date, withdrew the assumption that the personal filings covered the position, and prepared the trust's own returns for the open years. The engagement produced a filed record in the correct filer's name and a short memorandum on who files what going forward, so the beneficiaries' returns and the trust's no longer overlap or contradict each other.

Case study 6

Ownership review that concluded no affiliate return was due

A client had been told by a previous adviser that a small shareholding in a foreign company put them into the affiliate return, and wanted the years filed. We tested the ownership level against the affiliate measure before preparing anything, working from the share register and the successive rounds of issue that had diluted the holding. The conclusion was that the affiliate test was not met in any of the years, while the property statement was due throughout. The engagement produced the outstanding property statements and a written position on why the affiliate return was not filed.

Case study 7

A Home Kept in Canada After the Move Abroad

A dwelling left available is the tie the CRA weighs most heavily, and its treatment differs depending on whether it is rented at arm's length. The file settles the residence position first and the rental reporting second.

Read how this one runs
Case study 8

First Canadian Return After Arriving Mid-Year

The arrival date splits the year and sets the cost base of what you brought with you. Getting that date and those values right is what determines whether a later sale is taxed on the whole gain or only on the part that accrued after landing.

Read how this one runs

All case studies — every published engagement in one place.

Core International & Cross-Border Tax Services

International Tax Planning & Advisory

Strategy and compliance for income, assets and families spread across borders.

One coordinating team: filings on every side of the border are sequenced so treaty relief and foreign tax credits are claimed once — and in the right country.

U.S. & Cross-Border Tax Returns

Dual filers: U.S. citizens in Canada and Canadians with U.S. income run two parallel systems — we prepare both, in the right order, every year.

Expat & Emigration Tax

The move year is its own project: the elections and valuations filed that year decide the next decade of both countries’ returns.

Non-Resident Canadian Tax

Default withholding is 25% of gross: elective returns routinely turn over-withheld rent and pensions into refunds.

Transfer Pricing & BEPS

Documentation prepared with the return is the cheapest insurance in international tax; reconstructing it during an audit is the most expensive.

Cross-Border Estates & Trusts

Wills drafted for one country routinely misfire in the other — deemed disposition here, estate tax there, credits in between.

Cross-Border Corporate Tax

Expansion raises the same four questions every time — entity, PE, repatriation, payroll. We answer them before the tax authorities do.

India Tax for NRIs & Returning Residents

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.

Canadian Tax with a Foreign Element

Residency is decided on facts, not on a form — and the year you arrive or leave is the one where the largest amounts turn on the smallest details.

UAE Tax for Expats & Their Home Country

A zero-tax country is only half the answer — the question that decides the bill is whether the country you came from still treats you as resident.

Industries & Client Types We Serve Worldwide

Global E-commerce & Marketplaces
Technology & SaaS
Professional Services Firms
Cross-Border Real Estate
Importers, Exporters & Manufacturers
Athletes, Artists & Entertainers
Remote Workers & Digital Nomads
Investment Funds & Holding Companies

Global E-commerce & Marketplaces

  • Foreign VAT / GST / sales tax registrations
  • Marketplace withholding reviews
  • Inventory nexus & PE analysis
  • Multi-currency books reconciled
Explore E-commerce & Marketplaces

Technology & SaaS

Software revenue crosses borders by default — sourcing rules, withholding on licence-like payments and IP location decide the effective rate.

Software revenue is rarely taxed where the team sits. Licence, subscription and service income are characterised differently by each side, and the answer decides withholding at source, treaty relief and whether a foreign customer creates a taxable presence at all — questions that are cheap to settle before the contract and expensive afterwards.

  • Cross-border revenue sourcing & withholding
  • IP structuring with real substance
  • Equity for cross-border teams
  • U.S. expansion: entity & PE setup
Explore Technology & SaaS

Importers, Exporters & Manufacturers

  • Transfer pricing documentation (s.247)
  • Customs value vs transfer price
  • Foreign affiliate reporting (T1134)
  • Country-by-country reporting
Explore Trade & Manufacturing

Athletes, Artists & Entertainers

  • Reg 105 & U.S. CWA agreements
  • Multi-state & country calendars
  • Touring income allocation
  • Royalty & image-rights withholding
Explore Athletes & Entertainers

Remote Workers & Digital Nomads

  • Residency analysis before moving
  • Employer payroll exposure
  • Totalization & social security
  • Foreign tax credits
Explore Remote Workers

Investment Funds & Holding Companies

  • Treaty access & PPT reviews
  • FAPI & surplus computations
  • Withholding-efficient routing
  • Governance & substance
Explore Funds & Holdcos
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Ready to deal with T1135 vs T1134?

One short call, one fixed quote in writing, and your approval before anything is filed.

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Our practitioners are alumni of leading accounting and tax institutions

Where our partners studied — CPA Canada (In-Depth Tax Program), AICPA, the Institute of Chartered Accountants of India and the Malaysian Institute of Accountants.

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