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That US Amazon Balance Might Trigger a T1135. Your RRSP Won’t.
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That US Amazon Balance Might Trigger a T1135. Your RRSP Won’t.

Here is a filing that quietly catches Canadian Amazon sellers, because the trigger is sitting in a place most people never think of as "foreign property": your Amazon.com payout balance. It is the T1135, and the good news is that the account most sellers worry about, their RRSP, is not the problem.

What the T1135 is

If you are a Canadian tax resident and you own specified foreign property with a total cost over $100,000 CAD at any point in the year, you have to file a T1135 Foreign Income Verification Statement. It does not create a new tax. It is an information return that tells CRA you have offshore assets. Two details matter: the threshold is based on what the property cost, not its current value, and it can be tripped by things that do not feel "foreign" at all.

The part that surprises sellers

Your USD earnings sitting in your Amazon.com disbursement account count, because they are held by a US entity. So do balances in a Wise or Payoneer US account. Stack those against US stocks in a non-registered brokerage and the $100,000 cost threshold arrives faster than you would expect. Plenty of sellers cross it without realizing the form even exists.

The relief most people miss

Registered accounts are specifically excluded. Your RRSP, TFSA, RRIF, RESP, and RDSP do not go on the T1135, even when they are stuffed with US stocks and ETFs. Hold $200,000 of US equities inside your RRSP and you report none of it. The registered wrapper exempts it entirely. So the instinct to panic about the US holdings in your retirement account is backwards. It is the unregistered, operational money (the marketplace balance, the foreign bank account, the taxable brokerage) that counts.

Why you do not want to skip it

The penalties are steep for an information form. Late filing runs $25 a day up to $2,500, gross negligence can reach $12,000, and being more than two years late adds a further penalty on the cost of the unreported property. CRA can also extend how far back it can reassess you from three years to six. For a form that does not even cost you tax, that is a lot of downside for ignoring it.

We laid out exactly what counts, what does not, and the seller-specific scenarios in a table on our firm's site: Do I Include RRSP and TFSA on T1135 Foreign Property Reporting?

Not sure if your Amazon.com balance has pushed you over the line? That is exactly the kind of thing we check for sellers, and we share the plain-English version in the newsletter.

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