Last reviewed 2 September 2026 · Checked against the Income Tax Act and CRA guidance · By the CryptoNorth Team
Most Canadians do not. Form T1135 only applies if two things are true at once: the total cost of your foreign property passed $100,000 at some point in the year, and your crypto counts as being held outside Canada.
If you buy through a Canadian exchange like Bitbuy, NDAX or Shakepay, the CRA has said that crypto will typically not be treated as held outside Canada — so the second test usually fails and no T1135 is required.[3]
The Foreign Income Verification Statement is an information return, not a tax bill. Filing it costs you nothing in tax. It simply tells the CRA that you hold property abroad, so that foreign income has a harder time going unreported.[5]
You file it if you are a Canadian resident and, at any time in the year, the total cost of all your specified foreign property was more than $100,000. The Income Tax Act defines that term to include:[1]
“funds or intangible property, or for civil law incorporeal property, situated, deposited or held outside Canada”[1]
That phrase is what drags crypto into the conversation, and it is where the whole question turns.
This is the single most misunderstood part of T1135, and getting it backwards sends people in both wrong directions. The threshold uses the cost amount — broadly what you paid — not the market value.[2]
“based on the cost amount. The cost amount is defined in subsection 248(1) of the Income Tax Act and generally is the adjusted cost base and not the fair market value.”[2]
You bought 2 BTC on a foreign platform in 2020 for $30,000 all in. It is worth $250,000 today. Your cost amount is still $30,000, so this holding does not put you over the $100,000 line.
You put $120,000 into altcoins on a foreign exchange and they are now worth $40,000. Your cost amount is $120,000. You are over the line, and a bad year does not excuse you.
Two more details that catch people:
Newcomers to Canada: you do not file T1135 for the year you first became a resident.[2] From the following year, the cost amount of property you already owned is its market value on the day you became resident — not what you originally paid for it abroad.
Crypto has no physical location, which makes “situated, deposited or held outside Canada” awkward to apply. The CRA addressed this directly at the CPA Canada Roundtable on 29 August 2023, and its answer is more useful than most pages give it credit for.[3]
First, it confirmed crypto is capable of being specified foreign property at all, describing it as “funds or intangible property”. Then it declined to give a single rule:
“The question of whether cryptocurrency belonging to a taxpayer is situated, deposited or held outside Canada is complex.”[3]
But it did give one clear, practical answer, and it is the one that covers most Canadians:
“where CTPs are resident in Canada and comply with Canadian regulations, cryptocurrency held through such CTPs for the benefit of Canadian clients will typically not be considered as ‘situated, deposited or held’ outside Canada.”[3]
“CTP” is the CRA’s shorthand for a crypto trading platform — an exchange.
How we reached this: the exchange rows come straight from the CRA’s own words. The self-custody row does not, because the CRA has never addressed self-custody. With no intermediary anywhere, there is a reasonable argument that keys held by a Canadian resident in Canada are not held outside Canada — but that is an argument, not a ruling, and we are not going to dress it up as one. If self-custody is what puts you near $100,000 of cost, this is the point to call a CPA.
Worth knowing precisely, because the scary numbers quoted online are usually the gross-negligence ones, which need the CRA to show you knew better.[4]
There is a quieter consequence that matters more than the fines. If you did not report income from foreign property and the T1135 was missing, late or wrong, the CRA’s window to reassess that year extends by three extra years.[2] A return you thought was closed stays open.
T1135 is due on the same date as your tax return — for most people, 30 April.[2] There are two ways to complete it:
For a total cost under $250,000 all year. You tick the categories of property you held and report income by country — no asset-by-asset listing.
Required once the total cost hits $250,000 at any point. This one wants specifics: maximum cost during the year, cost at year end, income, and gains or losses.
Between $100,000 and $250,000 you may choose either.[2] Note that property inside an RRSP or TFSA is excluded from T1135 entirely — though you cannot hold crypto directly in either anyway.
If you buy and hold on a Canadian registered exchange, this form is almost certainly not your problem, and pages that imply every crypto holder must file it are scaremongering. The CRA’s 2023 statement is the reason, and it is quotable.
Take it seriously in three situations: you hold a large position on a foreign platform, your total cost of all foreign property is near $100,000, or self-custody is doing the heavy lifting. The last one has no official answer, and anyone who tells you otherwise is guessing.
Remember T1135 is separate from reporting your gains. Filing it does not report a disposition, and reporting a disposition does not satisfy it. See the main tax guide for the gains side.
No, not on buying or selling it — but you do when you spend it, and NFTs are treated differently.
Not yet. The rule that would make them is deferred to 2027 and is not yet law.
Cost amount for T1135 starts here — Canada uses average cost, not FIFO.
9 platforms authorized by the CSA, compared on fees and coverage.
This page is general information, not tax advice. We are not accountants. Whether your crypto is held outside Canada depends on your own facts, and the CRA has expressly called that question complex. If you are near the $100,000 cost threshold, or self-custody is a large part of your holdings, speak to a CPA who handles crypto rather than relying on this page.
9 exchanges registered with the CSA, compared on real CAD fees — and we show which ones pay us a commission.
Compare Canadian exchanges →