A Canadian seller running a US-focused Amazon or Shopify business often holds balances outside a Canadian bank account without thinking of it as a foreign investment: a US-based Seller Central payout account, a Payoneer or Wise balance held in USD, or funds sitting with a US payment processor before transfer to Canada. Some of these balances can count as specified foreign property for CRA’s T1135 Foreign Income Verification Statement, and the threshold is measured at cost across all such holdings combined, not per account.
T1135 Applies to Sellers the Same Way It Applies to Any Taxpayer
T1135 requires any Canadian resident individual or corporation holding specified foreign property with a combined cost amount exceeding CAD $100,000 at any point in the year to file the form, separate from the T1 or T2 return itself. There is no seller-specific exemption and no requirement that the property have generated reportable income; a foreign balance sitting idle still counts toward the threshold if it otherwise qualifies as specified foreign property.
The CRA’s T1135 guidance sets out the categories of specified foreign property and the filing requirement in full. What is less obvious to a seller is which of the account types common to cross-border e-commerce actually fall into those categories.
Which Seller Accounts Can Count
A foreign brokerage or investment account holding funds converted into US securities or other foreign investments is squarely within the category, the same as it would be for any Canadian investor.
A bank account held at a US financial institution, including a US-dollar business account opened specifically to receive marketplace payouts, generally counts as specified foreign property once it is genuinely a foreign-held account, distinct from a USD-denominated account held at a Canadian bank.
A payment processor balance held with a foreign entity, such as funds sitting in a US-domiciled Payoneer or similar account before transfer, is assessed on the same basis as a foreign bank balance: the question is where the account is legally held, not simply the currency it is denominated in.
Amazon Seller Central payout balances are less straightforward, since the balance represents funds owed by Amazon rather than a deposit account in the traditional sense, and the specific characterization can depend on how the payout structure works for the seller’s marketplace and settlement arrangement. This is a case where confirming the correct treatment with a professional, rather than assuming either that it counts or that it does not, is worth doing before relying on either assumption.
The Threshold Is Combined, Not Per Platform
The CAD $100,000 test applies to the total cost amount of all specified foreign property held, combined across every account and platform, not to any single account viewed in isolation. A seller with a US bank account holding USD $60,000 in cost and a separate foreign payment processor balance with USD $50,000 in cost has crossed the combined threshold even though neither account alone looks large enough to trigger the requirement.
This is the same combined-threshold structure that applies to any Canadian taxpayer with multiple foreign holdings, and it means a seller running payouts through more than one US-facing platform or processor needs to track the total across all of them, not evaluate each payout account independently.
Corporate vs. Personal T1135
An incorporated seller’s business holds its own foreign accounts and payout balances separately from anything the shareholder holds personally, and the corporation files its own T1135 alongside its T2 return if the corporation’s specified foreign property crosses the threshold. This is a separate filing obligation from any T1135 the individual owner may need to file personally for foreign holdings outside the corporation.
A seller who incorporated partway through building out US-facing sales channels should confirm which entity, the individual or the corporation, actually holds each foreign account, since the answer determines which entity’s T1135 filing, if any, the balance is measured against.
What to Review Before Filing
- The combined cost amount of every foreign-held bank account, payment processor balance, and brokerage account used in the business, not the balance in any single account
- Whether each account is genuinely held at a foreign institution, versus a USD-denominated account held at a Canadian bank, which does not itself trigger the requirement
- Whether Amazon Seller Central or another marketplace payout structure requires a specific determination rather than a default assumption
- Whether the corporation and the individual owner hold separate foreign balances that need to be tracked and measured against the threshold independently
Common Mistakes
Assuming a US-dollar balance is automatically outside CRA’s reach. The currency a balance is denominated in does not determine whether it is specified foreign property; where the account is legally held does.
Evaluating each payout platform separately instead of combining balances. A seller running Amazon, Shopify, and a separate payment processor can cross the combined threshold without any single account looking large enough on its own.
Treating a marketplace payout balance the same as a straightforward foreign bank account without confirming the characterization. Payout structures vary by platform and are not always a simple analog to a foreign deposit account.
Related Guides
- Foreign Exchange and Multi-Currency Payouts for Canadian E-Commerce Sellers covers the related question of how USD payouts and currency conversion flow through a seller’s books.
- US Sales Tax Nexus for Canadian E-Commerce Sellers covers a separate US compliance obligation that often comes up alongside foreign account questions for cross-border sellers.
- T1135 for Foreign Assets and USD Investment Accounts on the Teplov CPA side covers the core T1135 threshold and penalty mechanics in more detail.
Scope of This Guide
This guide covers how common cross-border e-commerce account types are assessed against the T1135 specified foreign property threshold. It does not cover:
- The full list of specified foreign property categories beyond those typical for a seller’s business
- T1135 penalty calculations and Voluntary Disclosures Program mechanics
- State-level or provincial tax obligations arising from US-facing sales activity
If your business holds US bank accounts, foreign payment processor balances, or Amazon payout balances and you have not confirmed whether the combined total crosses the T1135 threshold, that is worth reviewing before your next filing deadline.
Get in touch to review which of your foreign-held accounts and balances need to be tracked against the T1135 threshold.