Canadian tax residents do not need to report RRSPs, TFSAs, or other registered accounts on the T1135 Foreign Income Verification Statement, even if those accounts hold foreign investments. According to CRA, the T1135 is required when you own specified foreign property with a total cost exceeding $100,000 CAD at any time during the tax year, but registered accounts such as RRSPs, TFSAs, RESPs, and RDSPs are specifically excluded from this requirement. The $100,000 threshold is based on cost, not current market value.
Last updated: March 2025
What Is the T1135?
According to CRA, the T1135 (Foreign Income Verification Statement) is an information return that Canadian tax residents must file if they own specified foreign property with a total cost of more than $100,000 CAD at any time during the tax year.
The T1135 does not create a separate tax — you are already paying tax on the income. It is an information return that helps CRA track offshore assets and ensure foreign income is being reported.
Important: According to CRA, the $100,000 threshold is based on the cost of the property, not the current market value. If you bought US stocks for $110,000 CAD and they dropped to $80,000, you still need to file because the cost exceeded $100,000.
Are RRSPs and TFSAs Reported on the T1135?
No. According to CRA’s T1135 guidelines, registered accounts are specifically excluded from the definition of “specified foreign property.” This includes:
- RRSP (Registered Retirement Savings Plan)
- RRIF (Registered Retirement Income Fund)
- TFSA (Tax-Free Savings Account)
- RESP (Registered Education Savings Plan)
- RDSP (Registered Disability Savings Plan)
- DPSP (Deferred Profit Sharing Plan)
- RPP (Registered Pension Plan)
So if you hold $200,000 worth of US stocks inside your RRSP, you do not report that on the T1135. The registered account wrapper exempts it entirely.
What IS Included on the T1135?
According to CRA, specified foreign property that must be reported includes:
Financial Accounts
- Funds held in bank accounts outside Canada (US checking accounts, PayPal balances held in the US)
- Foreign currency holdings in non-Canadian institutions
Investments
- Shares of foreign corporations held in a non-registered brokerage account (even if traded on a Canadian exchange like the TSX)
- Foreign mutual funds and ETFs held outside registered accounts
- Foreign bonds and debt instruments
Real Estate
- Real property located outside Canada (rental properties, vacation homes used partly for income)
- Exception: According to CRA, personal-use property (a vacation home you never rent out) is excluded
Other Property
- Foreign patents, copyrights, or trademarks
- Interests in foreign trusts (unless reported on T1141 or T1142)
- Precious metals held outside Canada
Common T1135 Situations for Amazon Sellers
Based on our experience working with Canadian e-commerce sellers, Amazon sellers frequently trigger T1135 requirements without realizing it:
| Situation | Counts Toward $100K Threshold? | Why |
|———–|——————————-|—–|
| Amazon.com USD disbursement balance | Yes | Funds held by a US entity |
| US bank account (Wise, Payoneer) | Yes | Foreign financial account |
| US stocks in non-registered account | Yes | Foreign securities outside registered plan |
| RRSP holding US ETFs | No | Registered account exemption |
| TFSA holding US stocks | No | Registered account exemption |
| Amazon.ca CAD balance | No | Canadian entity, Canadian dollars |
Amazon.com Disbursement Account
If you sell on Amazon.com, your USD earnings sit in your Amazon disbursement account before transfer. According to CRA guidance, if this balance plus any other foreign property exceeds $100,000 CAD at any point during the year, you may need to file.
US Bank Accounts
Many Canadian Amazon sellers open US bank accounts through services like Wise or Payoneer to receive Amazon.com payments. According to CRA, these balances count toward the $100,000 threshold.
What Happens If You Do Not File?
According to CRA, penalties for failing to file the T1135 include:
| Penalty Type | Amount |
|————-|——–|
| Late filing | $25 per day, up to $2,500 |
| Gross negligence | $500 per month, up to $12,000 |
| More than 24 months late | Additional 5% of total cost of unreported property |
| Extended reassessment period | CRA can reassess 6 years back (instead of normal 3) |
The penalties can add up quickly, making T1135 compliance one of the most important filing obligations for Canadians with foreign assets.
Simplified vs. Detailed Reporting
According to CRA, there are two reporting methods:
- Simplified method: Total foreign property cost between $100,000 and $250,000 — check boxes and provide summary information
- Detailed method: Total exceeds $250,000 — provide details for each foreign property including country, income earned, and cost
Filing Deadline
According to CRA, the T1135 is due on the same date as your tax return:
- Individuals: April 30 (or June 15 if self-employed, though any balance owing is still due April 30)
- Corporations: 6 months after the fiscal year-end
Frequently Asked Questions
Do I need to report RRSP and TFSA holdings on the T1135?
No. According to CRA, registered accounts including RRSPs, TFSAs, RRIFs, RESPs, and RDSPs are specifically excluded from T1135 reporting, even if they contain foreign investments such as US stocks or international ETFs. The registered account wrapper exempts them.
Does my Amazon.com seller balance count toward the T1135 threshold?
Yes. According to CRA, funds held by Amazon.com (a US entity) in your disbursement account are considered specified foreign property. If this balance plus other foreign property exceeds $100,000 CAD at any point during the year, you must file the T1135.
What is the penalty for not filing a T1135 in Canada?
CRA charges $25 per day for late filing (up to $2,500), $500 per month for gross negligence (up to $12,000), and an additional 5% penalty on total unreported foreign property cost if more than 24 months late. CRA can also extend the reassessment period from 3 years to 6 years.
Is the T1135 threshold based on cost or market value?
According to CRA, the $100,000 threshold is based on the cost of the foreign property, not its current market value. If you purchased foreign assets for $110,000 CAD and they declined to $80,000, you still must file because the cost exceeded the threshold.
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Need Help Determining If You Need to File a T1135?
Foreign property reporting can be tricky, especially for e-commerce sellers with US marketplace income and multiple foreign accounts. If you are unsure whether you need to file a T1135, contact us. We work with Canadian Amazon sellers and online business owners every day and can make sure you are compliant.
For more information, see the CRA’s T1135 FAQ page.