US IRAs, the C$100k threshold, and the T1135

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Agcanuck
Posts: 1
Joined: Thu Jan 30, 2020 5:37 pm

US IRAs, the C$100k threshold, and the T1135

Post by Agcanuck »

Hi -

New poster, searched through the website and couldn't find an answer to this question so I'm hoping to get one with this thread.

Pertinent facts:
- US citizen, in Canada since 1992, became permanent resident of Canada since 2003
- Before moving to Canada, worked for two companies and contributed to registered accounts (IRAs). These accounts are managed by Fidelity in the US. I don't remember declaring these accounts to the CRA when I moved - hoping this isn't a mistake.
- I have no other US property other than these registered accounts, there are no Roth funds in them, and I have made no transfers to or withdrawals from these accounts after moving to Canada
- For the first time in 2019, the cost of these accounts is > C$100,000 which means I have to check the box on my Canadian tax return for the first time on the 2019 return
- My research suggests that I do not need to file a T1135 b/c registered accounts (aka IRAs andn 401ks) are not "specified foreign property".

My questions:
1. Do I understand the rules correctly around checking the box and filing T1135 requirements?
2. This is the first time I'm checking the box. If I were the CRA, I'd expect a T1135 to be submitted with my return but this is not the case for "non-specified property" such as IRAs (my understanding). Do I need to make a declaration of some sort to ensure the CRA understands that though I exceed the C$100k threshold, no T1135 is necessary?

Any help would be appreciated.

Thanks!
cnmcclain
Posts: 1
Joined: Tue May 19, 2020 3:40 pm

Re: US IRAs, the C$100k threshold, and the T1135

Post by cnmcclain »

I am very interested in the answer to this question, wondering if income in IRA's and Roth IRA's, as well as gains (e.g., shares sold), need to be reported on the T1135? Thanks!
mm77mm77
Posts: 20
Joined: Fri May 15, 2020 11:42 am

Re: US IRAs, the C$100k threshold, and the T1135

Post by mm77mm77 »

My understanding is that you only need to fill the form if your ACB (=cost, not FMV) is more than >100K.
You say you have not made any transfers to these accounts since 1992.
So, your ACB should not have changed, unless it's due to FX rate??
mm77mm77
Posts: 20
Joined: Fri May 15, 2020 11:42 am

Re: US IRAs, the C$100k threshold, and the T1135

Post by mm77mm77 »

Unless you had Return of Capital or bought more shares or Reinvested dividends of course... sorry wasn't sure I understood your situation correctly
nelsona
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Joined: Wed Oct 27, 2004 2:33 pm
Location: Nowhere, man

Re: US IRAs, the C$100k threshold, and the T1135

Post by nelsona »

IRAs are not subject to the T1135 reporting.
nelsona non grata. Non pro. Search previous posts. Happy Browsing :D
Fug1
Posts: 47
Joined: Sun Mar 09, 2014 12:00 pm

Re: US IRAs, the C$100k threshold, and the T1135

Post by Fug1 »

Does the T1135 reporting exemption for IRAs also extend to Roth IRAs? I recall being told by my accountant that Roths are considered pensions if the one-time Roth election is filed, but I'm wondering if this is specified anywhere by CRA.
Fug1
Posts: 47
Joined: Sun Mar 09, 2014 12:00 pm

Re: US IRAs, the C$100k threshold, and the T1135

Post by Fug1 »

I found the answer to my question, here in section 1.22:

https://www.canada.ca/en/revenue-agency ... h-ira.html

In short, the CRA does not require the Roth IRA information to be included in form T1135 if the Roth election has been filed and no Canadian contribution has been made.
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