New form T1135: What’s changed?

The Canada Revenue Agency (CRA)’s new version of Form T1135 for reporting foreign property is now available. Find out what’s new.

The latest version of the CRA’s Form T1135 Foreign Income Verification Statement — available for download from the agency’s website — enables taxpayers who qualify to use the new simplified reporting method announced in Budget 2015.

For 2015 and later years, if the total cost of a taxpayer’s specified foreign property is more than $100,000 and less than $250,000 throughout the year, the taxpayer will be able to report these assets to the CRA under a new simplified foreign asset reporting method. This method allows taxpayers to tick a box for each type of property they held during the year, and indicate the “top three” countries where the property was held, rather than providing details for each property.

The current detailed reporting requirements continue to apply to taxpayers with specified foreign property that has a total cost at any time during the year of $250,000 or more. If you qualify for simplified reporting, you still have the option to use the detailed method.

Taxpayers may use the 2015 version of Form T1135 for the current and future years. For previous years, taxpayers should use the form in existence at that time; however, administratively, the CRA will accept the current version of the form for previous years. Taxpayers can also use the simplified reporting method for previous years, as long as they meet the requirements.

More clarity on reporting requirements

The CRA’s description of changes notes that the aggregate reporting method continues to apply to taxpayers who have an account with a Canadian registered securities dealer and offers details on how to determine the value of the property in these accounts.

For taxpayers with reportable assets in more than three countries, the CRA’s updated Q&A on T1135 reporting also clarifies how to determine the top three countries for the new simplified method. First, you aggregate the month end cost amount of all specified foreign property on a country-by-country basis. Then choose the top three countries based on the highest month end cost amount.

It’s great to see simplifications like these and some tax preparers and taxpayers could find the reporting burden lighter for future T1135 filings.

However, as Chartered Professional Accountants of Canada (CPA Canada) has called for in representations to the government (discussed in this article), more could be done to ease the requirements while meeting the CRA’s goal of gathering the data it needs to enforce tax compliance. Among other things, the current filing deadline could be extended and the reporting of foreign securities held in accounts with registered Canadian securities dealers could be excluded entirely.

For more details on the Form T1135 requirements, see CPA Canada’s Q&A, which answers about 150 questions received during our November 2014 webcast.


Post a comment below. What are your views on this newly modified form? Will this simplification ease foreign asset reporting? Is there more that could be done to ease the Form T1135 filing burden, recognizing the CRA’s responsibility to protect the tax base?

CPA Canada’s Tax Blog is designed to create an exchange of ideas on tax policy and practice issues, and their impact on those who practise tax. Your comments can provide helpful input into the public interest advocacy positions developed by CPA Canada.

About the Author

Gabe Hayos, FCPA, FCA, ICD.D

Vice-president, Taxation, CPA Canada