T1135 And Crypto: Do You Have To Report Foreign Property?

Hardly anyone searches this, and that is exactly why people get it wrong. A reader once told me that because he bought on an app with a Canadian name, none of it could be foreign. That may be true. It may also not be. This page lays out what the CRA actually says, where it goes quiet, and what accounting firms read into the silence, with each source named so you can weigh it yourself. I am not a tax professional and this is not tax advice.

Sources: CRA Form T1135 Q&A, Foreign Income Verification Statement page and foreign reporting penalties page on canada.ca, reviewed October 2, 2026. The firm readings come from their published guides as summarized in search results; I did not rely on them for any number.

Do You Have To Report Crypto On Form T1135?

The CRA's rule is about specified foreign property with a total cost above CAD 100,000 at any time in the year. The word that matters is cost, not market value, and the total counts everything in the category together: foreign bank accounts, shares held outside Canada, foreign rental property and anything else that qualifies. Crypto would be one line in that total, if it qualifies at all.

The CRA's published T1135 pages describe the category as funds or intangible property situated, deposited or held outside Canada. They do not say whether crypto is funds, intangible property, or neither, and they do not say where crypto is “situated.” A cryptocurrency does not sit in a place the way a bank account does. That is the gap. Some Canadian accounting and advisory firms, including Metrics CPA and Block3 Finance in their published guides, read the rule as covering crypto held on foreign-based exchanges or in wallets whose keys are held abroad. That is their interpretation. Treat it as a cautious reading, not as CRA policy.

Where Is Your Crypto Held? Why Custody Matters More Than The App's Name

Because the open question is location, the practical step is to know who holds your coins. The platforms I rank differ.

A Canadian entity does not settle the question, because the entity can use custodians elsewhere. Coinbase's own agreement names US affiliates. For Bull Bitcoin and Bitcoin Well, the question moves to your wallet: a hardware wallet in your home does not obviously sit on a foreign server. Opinions differ, so ask about your own setup. My wallet guide covers the hardware side.

How Do You Work Out Whether You Are Over The CAD 100,000 Threshold?

1. List every account and wallet you held in the year, and for each one the Canadian dollar cost of what it held at its highest point. Cost, not value.
2. Add your other foreign property: foreign bank accounts, shares held outside Canada, and foreign real estate that is not for personal use.
3. Compare the total cost at any time in the year against CAD 100,000. The simplified Part A method applies if the total stayed under CAD 250,000 throughout the year.
4. If you are over, or close, ask an accountant how they treat your specific platforms and wallets and write the answer down.
5. File the T1135 with your return, on or before its due date. Keep exchange statements: the CRA says to keep records for at least six years from the end of the last tax year they relate to.

What Is The Penalty For Not Filing The T1135?

The CRA's penalty for filing late is $25 per day for up to 100 days, with a minimum of $100 and a maximum of $2,500. That is the figure on the CRA's own foreign reporting penalties page. If the failure is knowing or amounts to gross negligence, the CRA's penalty pages describe a heavier monthly penalty, $500 for each month the return is late, to a maximum of $12,000, and more again if the CRA has issued a demand. Interest on any arrears applies in addition. Against those numbers, an hour with an accountant is cheap.

Does Filing A T1135 Mean You Pay More Tax?

No. The T1135 is an information return. It does not itself tax your assets. Your income and gains are still reported under the normal rules. The CRA treats crypto as a commodity, and disposing of it by trading it for currency or another crypto-asset, or using it to buy goods and services, can be a disposition. Transferring crypto between wallets you own is not. For how the numbers work, read my tax guide and filing guide. If you use tax software, ask whether it supports the T1135; I could not confirm that for CoinTracker, see my review.

What If You Hold Crypto Through An ETF Or A Canadian Brokerage?

A Canadian-listed bitcoin ETF, such as the Purpose fund I cover in my BTCC ETF review, is a fund unit, not crypto. The T1135 question for securities depends on where they are held. The CRA's T1135 Q&A lets filers report aggregate amounts for property held with a Canadian registered securities dealer or a Canadian trust company in one category. That is a point for a tax professional, not a shortcut.

Will Platform Reporting Change This?

Yes, in one direction: more of what you hold will be visible to the CRA. Canada's draft crypto-asset reporting framework would have platforms report user details and transaction data to the tax authority. The government included it in Bill C-31, introduced on May 7, 2026. My CARF guide has the timeline, and my FINTRAC guide covers the separate anti-money-laundering reports. The safe assumption is that the CRA can see your exchange accounts, so report on that basis.