TL;DR: If on December 31 your combined foreign assets > $100K CAD (bank accounts in Ukraine + Europe, real estate in Ukraine, RSUs at a US broker, crypto on a foreign exchange, etc.) — you must file Form T1135 together with your T1 tax return. This is a reporting requirement, not a tax — but the penalty for late filing is $25/day, max $2,500/year + up to $12,000 in gross negligence cases. Most newcomers in their first year in Canada don't know about this and skip it. This post covers exactly what counts, what doesn't, and how to file correctly in 2026.

What T1135 is and why it matters

T1135 (Foreign Income Verification Statement) is a CRA form that reports all foreign assets that you own (or have beneficial interest in) as a Canadian tax resident. This is purely reporting, not taxation. That is:

You do NOT pay Canadian tax for merely owning foreign assets via T1135
You are required to report their existence and value every year
The penalty for a late or missing T1135 is separate from any tax penalty

Threshold: combined foreign assets cost > $100,000 CAD at any point during the tax year. If you held $100K+ for even one day — you must file.

⚠️ EMD compliance disclaimer: This is educational content, not tax advice. For individual T1135 filing — engage a Canadian CPA, especially one specializing in newcomers + cross-border (US/UA).

What counts as "foreign property" for T1135

CRA publishes a full list (CRA Form T1135 instructions), but for newcomers the most relevant are:

Category 1: Foreign bank accounts

Bank accounts in Ukraine (Pryvat, Mono, Oschad) — YES
Bank accounts in the US (Wells Fargo, Chase) for US-employer RSUs — YES
European bank accounts (Revolut, N26, Wise) if you hold a balance there — YES
Crypto on a foreign exchange (Binance, Coinbase outside Canada) — YES
Does not count: Canadian banks (RBC, Scotia, TD, Wealthsimple Cash)

Category 2: Foreign real estate

Apartment / house in Ukraine — YES (cost = original purchase price in CAD)
Inherited property — YES (cost = fair market value at inheritance)
Does not count: personal-use property used > 50% of the year (e.g. a summer cottage that you actively live in)

Category 3: Foreign securities held in foreign brokers

US stocks held at Schwab/Fidelity/IB-US (not IB-Canada) — YES
US-listed RSUs vesting through a US-based brokerage (E*TRADE, Schwab Equity) — YES
Ukrainian shares — YES
Crypto held on a foreign exchange — YES
Does not count: securities held at a Canadian broker, including US-listed stocks in your Wealthsimple/Questrade/RBC Direct account

Category 4: Foreign mutual funds / ETFs / pension plans

A European pension you've vested (UK SIPP, German Riester) — YES
Ukrainian NPF accumulations — YES
Does not count: Canadian RRSP/TFSA/FHSA/RESP

Category 5: Indebted to non-Canadian residents (Loans receivable)

Money loaned to family in Ukraine, expecting repayment — YES
Does not count: gifts (no expectation of repayment)

How the $100K threshold is calculated

Critical: the $100K threshold is based on cost amount in CAD, NOT current market value.

Examples:

Bought an apartment in Kyiv in 2018 for $80K equivalent CAD → cost = $80K (not the current market value of $120K).
$30K RSU vested in 2025 at a US broker → cost = $30K (fair market value at vesting day).
Bank balance of 100,000 UAH on Dec 31 = ~$3,500 CAD → cost = $3,500.

Convert at the CRA-approved exchange rate at time of acquisition (annual average rate, or year-end spot for current balances). Use Bank of Canada rates (bankofcanada.ca).

If aggregating across categories:

Kyiv apartment (cost $80K) + bank balance ($5K) + US broker stocks ($25K) = $110K total. Above the $100K threshold → must file T1135.

If everything combined < $100K: no T1135 required (BUT keep records — CRA can audit retroactively, and if your foreign assets later cross the threshold you'll need historical cost data).

Two simplified reporting tiers

T1135 has 2 reporting depths:

Simplified Method (< $250K combined foreign assets)

If your combined foreign assets are between $100K-$250K (cost basis):

Report type, top country, and aggregate cost ranges ($100K-$200K, $200K-$300K, etc.) per category
No need to report income from each property separately
Faster, less detailed

Detailed Method (≥ $250K combined)

If your combined foreign assets are $250K+ (cost basis):

Report each property separately with cost amount, max cost during year, income earned, gain/loss on disposition
Much more detailed — typically requires an accountant

Newcomer-specific patterns

Pattern 1: Just arrived (year 1)

You arrived from Ukraine in 2024:

Apartment in Kyiv ($80K cost) — YES
$5K cash at monobank — YES
$10K in a crypto wallet (foreign exchange) — YES
Total: $95K → under the threshold, T1135 NOT required for tax year 2024 ✓

Pattern 2: Year 2-3, accumulating Canadian wealth + retaining UA property

The same scenario, but in 2026:

Same apartment in Kyiv ($80K cost) — YES
monobank balance now $8K — YES
Crypto still $10K (didn't sell) — YES
Bought US-listed Apple stock at Wealthsimple (Canadian broker) — does NOT count for T1135
Total: $98K → still under the threshold ✓

But if a US-employer RSU vests at E*TRADE (US broker) for $20K:

Apt $80K + monobank $8K + crypto $10K + E*TRADE $20K = $118K → above the threshold → T1135 required

Pattern 3: Selling Ukrainian property and moving funds to Canada

If you sell your Kyiv apartment in 2026 for $120K (original cost $80K):

Capital gain $40K, taxable in Canada (50% inclusion = $20K added to income)
T1135 dispositions section required (income from foreign property)
Plus your T1 main return reports the gain
After the sale, if cash is transferred to a Canadian bank → cash is now in Canada, no longer foreign

How to file T1135

Step 1: Inventory all foreign assets at Dec 31

A spreadsheet with columns:

Asset description (e.g. "Apartment, Kyiv, 50 sq.m")
Country
Cost (in CAD, at date of acquisition or year-end rate)
Max cost during year
Income earned (rental, dividends, interest)
Capital gain/loss if disposed

Step 2: Determine reporting tier

Sum the cost column. If $100K-$250K → Simplified. If ≥ $250K → Detailed.

Step 3: File with your T1 return

T1135 paper version: download from canada.ca/T1135, fill it in, mail it with your T1 return. T1135 electronic: included in most tax software (StudioTax, UFile, TurboTax Premium).

Filing deadline: same as T1 — April 30 for most individuals, June 15 for self-employed.

Step 4: Keep records

CRA can audit up to 6 years after filing. Keep:

Original purchase agreements / bank statements showing acquisition cost
Year-end balance statements
Exchange rate documentation

Penalty math

If you fail to file T1135 by the deadline:

$25 per day late, max $2,500/year

If you knowingly hide foreign assets (gross negligence):

5% of missing asset value per year, max $12,000

If you file but the misstatement is material:

$24,000 penalty for a false statement + tax + interest

In 2024 CRA significantly upgraded enforcement on T1135 — they now cross-reference data with the US IRS, UK HMRC, and EU tax authorities (CRS — Common Reporting Standard).

Newcomer pitfalls

Pitfall 1: "My UA apartment isn't worth $100K" — forgot original cost

T1135 uses the cost amount in CAD at acquisition, not current market value. If you bought it in 2018 for $80K equivalent — that's the number. The current value of $120K is irrelevant for the threshold (relevant only for the sale capital gain).

Pitfall 2: Reporting only the year-end snapshot

The T1135 threshold is "at any point during the year". If during March RSU vesting your foreign assets briefly hit $110K but were back to $90K by Dec 31 — you must still file.

Pitfall 3: Forgetting Canadian-based foreign stocks

If you hold US stocks at a Canadian broker (Wealthsimple, Questrade) — these DON'T count for T1135 (held in Canada, the custodian is Canadian). An easy mistake leading to over-reporting.

Pitfall 4: Combined foreign assets just under $100K — don't file but no record-keeping

If you're at $95K total, no T1135 is needed THIS year. But next year you may cross the threshold — and you'll need historical cost data to file accurately. Keep records regardless of your current threshold position.

Pitfall 5: Crypto on foreign exchanges treated as "just crypto"

Binance/Coinbase outside Canada = a foreign asset for T1135 purposes. Many crypto holders miss this. Wealthsimple Crypto / NDAX (Canadian-based) = does NOT count.

What if you missed T1135 in past years

Voluntary Disclosure Program (VDP):

A CRA program for voluntarily disclosing missed past filings
Penalty waived or reduced for first-time good-faith disclosures
Must be filed BEFORE CRA initiates an audit
Generally only available once per taxpayer

Strategy: if you arrived in 2024, didn't file T1135 (didn't know), and now realize you should have — submit a VDP for the missed years immediately. Engage a CPA. The penalty is significantly lower than waiting for a CRA audit.

Action plan for the 2026 tax season

December 2025 / January 2026: inventory all foreign assets as of December 31, 2025
Convert to CAD at BoC rates (annual average for income, year-end spot for balances)
Determine threshold: total cost < $100K? No T1135 needed but keep records. ≥ $100K? File T1135 (Simplified if < $250K, Detailed if ≥).
Engage a CPA if it's your first time or a complex situation (cross-border income, multiple countries, rental property abroad)
File by April 30 (or June 15 if self-employed)

This post is part of a series on newcomer tax. The first-year checklist — Your first year in Canada: a financial checklist.

T1135 Foreign Property: when a newcomer to Canada must report