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T1135 and Interactive Brokers: do you need to file?

Updated: 21/10/2026

Do IBKR investors need Form T1135? The CAD 100,000 cost test, what counts as foreign property, simplified vs detailed reporting and the late-filing penalties.

You must file Form T1135 if the total cost of all your specified foreign property was more than CAD 100,000 at any time in 2025. US and other foreign shares held in a non-registered Interactive Brokers account count, even when the account is with a Canadian dealer, while anything held in a TFSA or RRSP does not.

• Shares of non-Canadian companies, including US stocks and US-listed ETFs, wherever the account is held.
• Funds held outside Canada, such as cash at a foreign broker or bank.
• Debts owed by non-residents, such as foreign bonds.
• Interests in non-resident trusts and funds.

It does not include:

• Property held in a TFSA, RRSP, RRIF or other registered plan.
• Canadian-listed ETFs and mutual funds, even when they hold US or global stocks.
• Personal-use property, such as a holiday home used mainly by you.

The test uses the cost amount — essentially your ACB, converted to CAD at the exchange rates of the purchase dates — not today's market value. A portfolio bought for C$90,000 that has grown to C$150,000 does not require a T1135. A portfolio that cost more than C$100,000 does, even if it has fallen in value.

The threshold applies to the highest total during the year, not just December 31. If you held the shares only for a few months, they still count.

Each spouse applies the threshold separately to their own share of a joint account, based on their ownership share.

You bought US shares for US$60,000 in 2023 when US$1 = C$1.35, a cost of C$81,000. In March 2025 you added US$20,000 more when US$1 = C$1.43, a cost of C$28,600.

• Total cost: C$81,000 + C$28,600 = C$109,600
• That is above C$100,000, so a T1135 is required for 2025, even if the market value at year end is lower.
• Because the total stayed under C$250,000 all year, the simplified method is available.

• Simplified method: if the total cost was over C$100,000 but under C$250,000 throughout the year. You tick the types of property you held, name the top countries, and report the total income and gains or losses.
• Detailed method: if the total cost reached C$250,000 at any time. Property is reported by category, with the maximum cost during the year, the cost at year end, and the income and gain or loss.

For property in an account with a Canadian registered securities dealer, the detailed method lets you report totals for each country instead of listing every holding. Interactive Brokers Canada is a Canadian dealer, which makes this much simpler for most of its clients.

1. Run Annual Activity statements for 2025 and every earlier year in which you bought positions still held, under Performance & Reports, then Statements.
2. For each foreign holding, calculate its cost in CAD from the purchase-date exchange rates.
3. Track the total cost through the year, adding purchases and removing sales, to find the highest point.
4. Group holdings by country of the issuer.
5. Add up the dividends, interest and capital gains or losses from that property for 2025.
6. Choose the method based on your highest total and file T1135 with your T1, usually electronically with certified tax software.

T1135 is due on the same date as your return, which for 2025 was April 30, 2026 (June 15 if you or your spouse had self-employment income). Filing late costs $25 a day, at least $100 and up to $2,500 for each year. Knowingly failing to file, or gross negligence, brings larger penalties of $500 a month for up to 24 months. A missing or incomplete T1135 also gives the CRA three extra years to reassess that return.

If you missed one or more years, filing as soon as possible limits the damage, and the CRA's Voluntary Disclosures Program may reduce penalties where the conditions are met.

• Testing the threshold with market value instead of cost.
• Looking only at December 31 and missing a higher total earlier in the year.
• Counting Canadian-listed ETFs that hold US stocks.
• Leaving out foreign shares because the broker is Canadian.
• Believing that no tax owing means no form is needed. T1135 is an information return, and penalties apply even when no tax is due.

A form that never changes your tax bill can still cost you $2,500 a year. Upload your IBKR statement to Brokers.tax to see the value of your foreign holdings in CAD next to the C$100,000 line, so you know whether a T1135 is on your list before a penalty puts it there.