Foreign Asset Reporting Threshold Calculator: Canadian Snowbird with $150K USD Brokerage Account

The Scenario: Canadian Snowbird with US Financial Assets

Here are the baseline assumptions for our worked example. The methodology applies to any Canadian resident with foreign property, but the numbers reflect a typical snowbird portfolio:

The critical number is $195,750 CAD — the cost amount of all specified foreign property. This is nearly double the $100,000 threshold, so there is no ambiguity about the filing requirement. Even if the brokerage account dropped to $80,000 USD in market value, the cost amount remains $175,500 CAD — the threshold is based on what you paid, not what it is worth today.

CAD/USD Conversion: Which Exchange Rate to Use

The conversion methodology trips up many snowbirds because the CRA requires you to use the exchange rate on the date of each acquisition, not a single year-end rate. For a brokerage account funded through multiple transfers over several years, this means tracking every deposit:

The Bank of Canada daily exchange rate is the authoritative source. You can look up historical rates on the Bank of Canada website. If you cannot find the exact date, the CRA will accept the average annual rate for the year of acquisition, but the daily rate is preferred and produces the most defensible filing. For snowbirds who have been transferring money to the US for a decade or more, reconstructing these records can be the hardest part of the T1135.

Which Assets Count as Specified Foreign Property?

Section 233.3 of the Income Tax Act defines specified foreign property broadly. Here is how common snowbird assets are classified:

The most common mistake snowbirds make is assuming their Florida condo is excluded. It is — but only if they never rent it. The moment you list it on Airbnb, VRBO, or through a local property manager for even a few weeks per year, the CRA classifies it as property held to earn income. At that point, the entire cost of the condo in CAD is added to your specified foreign property total. A condo purchased for $300,000 USD at a 1.30 exchange rate adds $390,000 CAD to your total, pushing you well into the detailed reporting method. For context on how Canadian rental properties work differently, see our article on Rental Property Depreciation in Alberta.

Simplified vs Detailed Reporting Method

The T1135 form has two parts, and the one you use depends on the total cost of your specified foreign property:

Our snowbird with $195,750 CAD in total cost qualifies for the simplified method. This is a significant relief — you check the boxes for "funds on deposit with a foreign entity" and "shares of non-resident corporations", and the form takes about 10 minutes to complete. If that same snowbird rents out their Florida condo (adding $390,000 CAD), the total jumps to $585,750 and the detailed method applies. That version requires listing every brokerage holding, every bank account, and the condo individually — a process that typically costs $500–$1,500 in accounting fees. To understand how registered accounts shelter you from this reporting burden, see RRSP vs TFSA Comparison.

Penalty Table: What Happens If You Have Not Filed T1135

The CRA takes T1135 non-compliance seriously because it is the primary mechanism for detecting unreported foreign income. Here is the penalty structure:

Here is what multi-year non-compliance looks like in dollar terms for a snowbird who simply did not know about T1135:

Threshold Calculation: When $100K USD Does Not Mean $100K CAD

Many snowbirds assume the $100,000 threshold is a simple currency conversion of their current portfolio balance. It is not. The calculation uses the cost amount (adjusted cost base) in Canadian dollars, converted at the exchange rate when each asset was acquired. This creates three common misconceptions:

• "My account is worth $80K USD, so I am under the threshold": If you deposited $110,000 USD over the years and the investments declined to $80,000, you still have a cost amount of $110,000 USD × ~1.35 = $148,500 CAD. You must file.
• "I converted my funds when USD/CAD was 1.00": If you transferred $95,000 USD when the rate was at parity, your cost is $95,000 CAD — under the threshold. But if you added $10,000 more when the rate was 1.35, your total is now $108,500 CAD. One small deposit pushed you over.
• "I only need to file for years when I was over $100K": Correct — but if you were over the threshold at any point during a tax year (even briefly), you must file for that entire year. If your account dipped below $100K CAD in cost on December 31 but was above it in March, you still file.

The Snowbird Checklist: Do You Need to File T1135?

Walk through this checklist for each tax year:

• Step 1: List all property held outside Canada — brokerage accounts, bank accounts, real estate that earns rental income, shares in foreign corporations, foreign bonds, and interests in foreign trusts or partnerships.
• Step 2: For each property, determine the cost amount in Canadian dollars using the Bank of Canada exchange rate on the acquisition date.
• Step 3: Add up all cost amounts. If the total exceeds $100,000 CAD at any time during the year, you must file T1135.
• Step 4: Determine the reporting method — simplified (Part A) if total cost is $100K–$250K CAD, or detailed (Part B) if over $250K CAD.
• Step 5: File T1135 with your T1 income tax return by the April 30 deadline (June 15 if self-employed, but any balance owing is still due April 30).

Exclude your RRSP, TFSA, RESP, and other registered plan holdings even if they invest in foreign securities. Also exclude personal-use vacation property, foreign currency held for personal travel, and US Social Security entitlements. For snowbirds approaching their first home purchase in Canada, note that FHSA accounts are also excluded — see FHSA Calculator for First-Time Buyers.

Voluntary Disclosure: Fixing Years of Non-Compliance

If you have held foreign assets above the threshold for multiple years without filing T1135, the Voluntary Disclosures Program (VDP) is the standard resolution path. The process works as follows:

• Pre-disclosure consultation: Engage a cross-border tax accountant to assess the scope of non-compliance — how many years, how much unreported income, and the estimated penalty exposure. This is critical because VDP applications are irrevocable once filed.
• File the application: Submit all outstanding T1135 forms and any amended T1 returns for years where foreign income was underreported. The VDP application must be voluntary (you cannot be under audit), complete (all years and all income), and include payment or a payment arrangement for all tax owing.
• CRA classification: The CRA classifies each application as either "general" relief (full penalty waiver, partial or full interest waiver) or "limited" relief (penalties reduced but not waived, interest only partially reduced). T1135-only non-compliance with no unreported income is typically classified as general relief. If there is also unreported foreign income, the classification depends on the amounts involved.
• Resolution: Once accepted, you pay any remaining tax and reduced interest. The T1135 penalties are typically waived entirely under general relief. Going forward, you file T1135 annually with your tax return.

The cost of a VDP application — including the accountant's fees and any back taxes — is almost always less than the accumulated penalties for continued non-compliance. A 5-year voluntary disclosure for a snowbird with $195K CAD in foreign assets typically costs $3,000–$6,000 in professional fees, versus up to $12,500 in penalties if the CRA discovers the non-filing first. For context on how the CRA handles capital gains on Canadian property, see Cottage Capital Gains in Ontario.

Real-World Example: Our Snowbird's Complete Filing

Returning to our snowbird with $175,500 CAD in brokerage cost and $20,250 CAD in bank accounts ($195,750 total), here is what the actual T1135 filing looks like for the 2025 tax year using the simplified method:

The income from the US brokerage (dividends, interest, realized capital gains) must also be reported on the T1 return itself — T1135 is an information return, not a tax return. The foreign tax credit for US withholding tax on dividends (typically 15% under the Canada-US tax treaty) is claimed on the T1 to avoid double taxation. For how foreign income interacts with your overall tax picture, try the CRA Tax Estimator.

Common Mistakes Snowbirds Make with T1135

Based on the most frequent errors we see:

• Using market value instead of cost: The threshold is based on cost amount. A portfolio that has doubled in value from $60K to $120K USD does not trigger T1135 if the cost in CAD is under $100K. Conversely, a portfolio that has lost money may still exceed the threshold based on what you originally paid.
• Forgetting the bank account: Many snowbirds track their brokerage account carefully but forget the US checking account with $20,000 sitting in it. Every dollar of foreign property counts toward the aggregate $100K threshold.
• Assuming RRSP foreign holdings need reporting: If your RRSP at a Canadian institution holds US stocks or international ETFs, those are not specified foreign property. The registered plan is the legal owner. However, if you hold an IRA at a US institution, that is a more complex situation — the IRA itself may be considered foreign property depending on the treaty provisions. For an overview of registered account strategies, see FHSA Calculator.
• Not filing because no tax is owing: T1135 is an information return. Even if your foreign property earned zero income and you owe zero additional tax, you must still file if the cost exceeds $100K CAD. The penalty applies to the failure to file the information return, not to any tax shortfall.
• Confusing T1135 with FBAR: FBAR (FinCEN Form 114) is the US equivalent — required for US persons with foreign accounts over $10,000 USD. Canadian snowbirds who are not US citizens or green card holders do not file FBAR. T1135 is the Canadian filing obligation. If you are a dual citizen, you may need both.

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Frequently Asked Questions