You had plenty of questions about Form T1135 and, now, some answers

More than 8,300 people attended CPA Canada’s webinar on Form T1135 and asked almost 150 different questions. Thanks to the presenters, and support from the Canada Revenue Agency, I’m now able to share some answers.

With so many questions, about rules that are so very complex, developing guidance hasn’t been easy. But given the need for this information — for taxpayers, tax preparers and investment community members as the 2014 personal tax filing season approaches — Chartered Professional Accountants of Canada (CPA Canada) is making the full list of questions available, along with as many answers as possible.

Some answers have been reviewed by the Canada Revenue Agency (CRA). Others didn’t require CRA input. About a third remains unanswered. And while the CRA is aware of them, it’s given us no assurances that it will respond. Where it does, naturally, we’ll provide those responses.

I want to stress that I continue to work with my fellow webinar presenters, Barbara Amsden (Investment Industry Association of Canada) and Hugh Neilson (Kingston Ross Pasnak LLP), together with Maureen Vance (Wolters Kluwer CCH), to develop further guidance and find ways to clarify the foreign income reporting requirements. The CRA is providing assistance as it considers appropriate.


The CRA has been open to discussing concerns about the administrative burden presented by Form T1135. Still, I believe, more can be done. In an effort to make some progress, I wrote a letter in December 2014 to the Ministers of Revenue and Finance suggesting what I felt were relatively straightforward changes to the form.

While CPA Canada recognizes that Form T1135 won’t be eliminated, we’ll continue to pursue options — and collaborate with the CRA and other stakeholders — to simplify its requirements in ways that would still allow the CRA to gather the information it needs to ensure compliance. Stay tuned.


Register to replay the webinar and to download the webinar Q&A, slides and other resources.


What solutions do you think the CRA should consider to ease Form T1135’s filing burden, recognizing its responsibility to protect the tax base? Post your comment below.

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