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ARTICLE · 29 JANUARY 2026

Foreign Assets Under The Microscope: Navigating Today's T1135 Audit Push

Borden Ladner Gervais LLP
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Many Canadians hold foreign investments, ranging from offshore bank accounts to international real estate and securities.

CanadaTax
Kevin Bianchini
Kevin Bianchini
Noah Weinstein
Noah Weinstein
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Many Canadians hold foreign investments, ranging from offshore bank accounts to international real estate and securities. In recent years, we have noticed that the Canada Revenue Agency (CRA) has significantly increased its scrutiny of these holdings, leading to a noticeable uptick in audits focused on foreign income and asset reporting. This trend underscores the importance for taxpayers to ensure full compliance with their disclosure and reporting obligations.

What is form T1135?

Form T1135 must be filed by Canadian resident individuals, corporations, and certain trusts that, at any time during the year, own specified foreign property (SFP) exceeding $100,000, and certain partnerships that own SFP valued at more than $100,000. It is worth noting that the $100,000 cutoff is based on the total cost amount and not the fair market value of the SFP, as is defined in s. 248(1) of the Income Tax Act (Tax Act).

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