Cross-Border Tax · Guide
T1135: who has to file, deadlines, and penalties
You must file Form T1135 with the CRA if the total cost of your "specified foreign property" was more than $100,000 CAD at any time in the year. It is due with your income tax return, and filing late costs $25 per day (minimum $100, maximum $2,500 per year) — even if you owe no tax on the property itself.
By the AnalytIQ Accounting team · Last reviewed: August 12, 2026
What counts as specified foreign property
Specified foreign property includes funds in foreign bank accounts, shares of foreign corporations (including US stocks held in Canadian non-registered brokerage accounts), foreign rental real estate, and debts owed by non-residents. It does not include property inside RRSPs, RRIFs, or TFSAs, US property used mainly for personal use (like a vacation home you don't rent out), or shares held through Canadian mutual funds.
The $100,000 threshold is about cost, not value
The test is the total cost amount (usually what you paid, in Canadian dollars) of all specified foreign property combined — not today's market value, and not per property. If your combined cost crossed $100,000 CAD at any point in the year, even briefly, you file for that year.
Two ways to report
If your total cost was under $250,000 CAD all year, you can use the simplified method — tick boxes by category and report totals. Over $250,000, the detailed method applies: each property, its country, its highest cost in the year, and the income it produced.
Deadlines and penalties
T1135 is due the same day as your income tax return. The late-filing penalty is $25 per day to a maximum of $2,500 per year, and it applies per year missed — several missed years multiply the exposure. Higher penalties exist for knowing or grossly negligent failures.
Missed a year? Fix it before the CRA asks
The CRA's Voluntary Disclosures Program can reduce or eliminate penalties for unfiled T1135s — but only if you come forward before the CRA contacts you. This is one of the most common cross-border cleanups we handle: we file the missed forms, prepare the disclosure, and get you current.
Common questions.
Do US stocks in my Canadian brokerage account count?
Yes, if the account is non-registered — US shares are specified foreign property even when held at a Canadian broker. Inside an RRSP or TFSA they do not count.
Does my Florida vacation home count?
Not if it is mainly for personal use and not rented out. If you rent it, it becomes specified foreign property.
Is T1135 the same as FBAR?
No — T1135 is Canada-side (CRA). FBAR is the US-side equivalent for US persons. Cross-border families often need both; we prepare them together so they agree.
Related reading
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