How should I report foreign Restricted Stock Unit (RSU) awards on T1135?

As part of my compensation, my employer awards restricted stock units (RSUs) of an American company at various times in the year. These are held in an American account.

Each time the RSUs vest, the employer sells a certain number of shares to cover withholding tax.

I think I should report this on T1135 in the following manner, but I'd like to confirm whether this is correct.

- Report under category 2, 1. Report under category 2, "Shares of non-resident corporations (other than foreign affiliates)"

- "Maximum cost amount during the year": Set to zero, as I have no cost/ACB due to not having purchased these shares myself.

- "Gross income": report the gross Canadian-dollar value at the time the RSUs vest. Example: On February 2018 I get 10 shares vesting at a price of $9CAD/share, and 4 are sold for tax purposes. On September 2018 I get 5 shares at a price of $8CAD/share, and 2 are sold for withholding tax. Report 9*10 + 8*5 = $130

- "Gain (loss) on disposition": report capital gain or loss, if I had sold any shares during the year. But for this reporting, should I count the ACB as zero, or should I calculate the ACB as if I had purchased the shares at fair market value on the vesting dates?


Also, if I had received RSUs in the previous year but my total foreign property ownership was under $100,000 in that year, do I need to report these RSUs somehow on T1135?