T1135 foreign property reporting

Your T1135 foreign property report, built from data you already have

If specified foreign property cost exceeded $100,000 at any point in the year, you may have to file a T1135. Sched3 calculates the cost timeline and gains, then requires you to review issuer residence, category, country, and gross income before export.

Check my T1135 statusCheck if you need a T1135

How it works

1
Your data is already here

Sched3 already tracks the cost base of every taxable-account holding in Canadian dollars. USD-denominated securities are surfaced as candidates, but currency alone is never treated as proof of issuer residence.

2
We identify what qualifies

Not all foreign exposure counts. You review each candidate's issuer residence, T1135 category and country, while registered-account property is excluded from the calculation.

3
Generate the T1135 data

Maximum cost during the year, cost at year-end, income earned, and gain/loss realized — broken out by category (shares, funds, property, other) exactly as the T1135 form requires.

What counts as specified foreign property

The CRA's definition is broader than most people think. Sched3 screens the ledger and blocks export until the classifications and income amounts are reviewed.

  • US-listed stocks and ETFs held directly (AAPL, VTI, QQQ, etc.)
  • Foreign bonds and debt instruments
  • Foreign bank accounts (combined with all other specified foreign property for the threshold)
  • Interests in non-resident trusts
  • Does NOT include Canadian-listed ETFs (even if they hold US stocks)
Maximum cost during the year — the threshold that catches people

The $100,000 threshold is based on the highest cost at any point during the year. If you bought $120K in US stocks in March and sold half in June, you still needed to file because you exceeded $100K during the year. Sched3 tracks the running maximum cost of your foreign holdings so you know whether you've triggered the requirement.

Included from the Active Investor plan

T1135 reporting is available on the Active plan. It uses the same holdings and FX data that powers your ACB tracking.

Free
$0

Manual entry, 1 portfolio, basic ACB & CSV export.

Investor
$49

Broker import, superficial loss detection, FX support, splits & DRIPs.

Active Investor
$129 · included

The full workflow: T5008/T3, traded options, crypto, equity comp, corporate actions and accountant export.

Accountant
Early access · included

Multi-client dashboard, client import links, bulk import, branded reports. Pricing shaped with early-access firms.

Frequently asked

Do I need to file a T1135?

If the total cost of all your specified foreign property exceeded $100,000 CAD at any time during the year, yes. This is based on cost (what you paid), not market value. A portfolio of US stocks that cost you $105,000 CAD to acquire requires a T1135, even if the market value dropped to $80,000.

What are the penalties for not filing?

The standard late-filing penalty can be $25 per day, up to $2,500. Higher demand-to-file and gross-negligence penalties can apply in specific circumstances. An inaccurate or late T1135 can also extend the normal reassessment period when the statutory conditions are met.

Does my Canadian-listed US-equity ETF (like VFV or XUU) count?

No. Canadian-listed ETFs are Canadian trusts, not foreign property — even if their underlying holdings are all US stocks. However, if you hold VTI or SPY directly (US-listed ETFs), those are specified foreign property and count toward the $100K threshold.

What about my TFSA or RRSP?

Registered accounts (TFSA, RRSP, RESP, RRIF) are completely excluded from T1135 reporting. Only holdings in non-registered (taxable) accounts count. This is the same scope Sched3 uses for ACB tracking.

Read: capital gains tax in Canada
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Not tax or legal advice. Always confirm capital gains reporting with a qualified accountant. · Made with love in Canada 🇨🇦
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