Do I Include RRSP and TFSA on the T1135? Foreign Property Rules for 2026

No. You don’t report your RRSP or TFSA on Form T1135, even if those accounts are full of US stocks. The T1135 Foreign Income Verification Statement is only required when the specified foreign property you hold outside registered accounts cost more than $100,000 CAD at any time in the year. Property held inside a registered plan such as an RRSP or TFSA doesn’t count toward that threshold at all, and the same reasoning covers RRIFs, RESPs, RDSPs, FHSAs, and registered pension plans, because the plan trust, not you, holds the property.

That’s the short answer. The longer answer matters because the form catches people who never think of themselves as owning “foreign property,” and the penalties for missing it are out of proportion to how simple the form is.

What the T1135 actually is

The T1135 is an information return, not a tax. You’re already paying Canadian tax on the income from these assets; the form exists so CRA can match offshore holdings against the income you report.

The $100,000 threshold is based on cost, not market value. CRA defines it as the cost amount, which is generally your adjusted cost base. If you bought US stocks for $110,000 CAD and they’ve dropped to $80,000, you still file, because cost is what counts. And “at any time during the year” means exactly that: if your foreign holdings crossed $100,000 in March and you sold everything in April, the filing requirement already triggered.

Why registered accounts don’t count

CRA’s own T1135 guidance confirms that specified foreign property held in an RRSP or a TFSA is excluded from the reporting requirement. The same result follows for RRIFs, RESPs, RDSPs, FHSAs, and registered pension plans, because in each case the plan trust holds the property rather than you. Hold $200,000 of US ETFs inside your RRSP and there’s nothing to report.

The wrapper is what matters, not what’s inside it.

Here’s the trap that flows from the same logic: a Canadian mutual fund that invests in US stocks isn’t specified foreign property either, because the fund itself is a Canadian entity. But a US-listed ETF or a non-resident fund held in your non-registered account is reportable. Two portfolios can hold identical underlying stocks and have completely different T1135 outcomes.

What does count

Specified foreign property includes, among other things:

• Funds in bank accounts outside Canada, including US chequing accounts and USD balances held with US institutions
• Shares of foreign corporations held in a non-registered account, and it makes no difference that your broker is Canadian
• Non-resident mutual funds and foreign ETFs held outside registered plans
• Foreign bonds and other debts owed by non-residents
• Real estate outside Canada that earns income, such as a rental condo
• Precious metals and certain other property held outside Canada

A vacation home used primarily for personal enjoyment is excluded as personal-use property; CRA reads “primarily” as more than 50%. Rent it out most of the year with a reasonable expectation of profit and it stops being personal-use. Property used exclusively in an active business is also excluded, and shares of a foreign affiliate fall under a separate return.

The e-commerce seller trap

This is where we see the most missed filings. If you sell on Amazon.com, your USD disbursement balance is money held by a US entity outside Canada, and it generally counts toward the threshold. So do USD balances with US-based providers like Wise or Payoneer. None of these feel like “foreign property,” but CRA’s definition starts with funds situated, deposited, or held outside Canada.

Everything aggregates. A $60,000 Amazon.com balance plus $45,000 of US stocks in a non-registered account puts you over $100,000, even though neither item does on its own. Between $100,000 and $250,000 there’s a shorter summary version of the form; at $250,000 or more, CRA wants more detail. Either way, the trigger question is the same.

What it costs to get wrong

The late-filing penalty is $25 per day, with a $100 minimum and a $2,500 maximum, and it applies even when no tax was avoided. Where CRA considers the failure to be knowing or grossly negligent, the penalty jumps to $500 per month for up to 24 months, to a maximum of $12,000, and past 24 months in those cases an additional penalty of 5% of the cost of the property can apply.

There’s a quieter consequence too: if the T1135 isn’t filed on time and you also failed to report income from specified foreign property, CRA gets three extra years to reassess your return.

The form takes minutes once your records are organized. The penalty math never works in your favour, which makes this one of the worst forms to gamble on. We file the T1135 as part of the tax returns we prepare for e-commerce sellers and investors with US accounts, so the threshold question gets asked every year instead of after a CRA letter arrives.

Frequently asked questions

Do I need to report my RRSP or TFSA on the T1135?

No. CRA excludes specified foreign property held in an RRSP or TFSA, and the same treatment applies to RRIFs, RESPs, RDSPs, FHSAs, and registered pension plans, even when those accounts hold US stocks or foreign ETFs. Only foreign property held outside registered accounts counts toward the $100,000 threshold.

Is the $100,000 threshold based on cost or market value?

Cost. CRA uses the cost amount, generally your adjusted cost base, measured in Canadian dollars. If your foreign property cost more than $100,000 at any time during the year, you file, even if its market value is lower by year-end.

Do US stocks held at a Canadian brokerage count?

Yes, if they’re in a non-registered account. Shares of non-resident corporations are specified foreign property regardless of which broker holds them. The same shares inside an RRSP or TFSA are excluded, and a Canadian mutual fund holding US stocks isn’t specified foreign property at all.

Does my Amazon.com seller balance count toward the T1135 threshold?

Generally yes. Funds held for you outside Canada, such as a USD account with a US institution, fall within CRA’s definition of specified foreign property, and a US marketplace disbursement balance will usually count as well. Combined with your other foreign holdings, these can push you past $100,000 without you noticing. Because the treatment can turn on how the balance is held, confirm before you rely on it.

Related guides

• How to get US dollar payments from Amazon.com back to Canada
• USD credit cards for Canadian businesses
• How to pay CRA with a credit card
• Personal tax services

Not sure whether you need to file?

If you’ve got US marketplace balances, a US bank account, or foreign investments outside your registered plans, the threshold question is worth five minutes before it becomes a penalty notice. Contact us and we’ll tell you whether a T1135 applies to you and take care of it with your return.