Is the T1135 "Max cost" specific to a single point in time like "Cost amount at year end"? Or does it span the year like "income" or "gain(loss) on disposition"?

[trussell]

During the year $80K (CAD) worth of US stock was bought, then sold. Then another $80K (CAD) of the same stock was bought, and then sold again. So on any particular day of the year, the max cost of stock held was $80K. However, if "max cost" is supposed to be cumulative, then the total cost over the whole year was $160k. Here's the wording:

"The total cost of all specified foreign property held at any time during the year exceeds $100K"

The meaning is not clear due to the "at any time". If the statement was "The total cost of all specified foreign property held during the year exceeds $100K", then that would be a strong indicator of the tally of all costs throughout the year.

[TurboTax-Terry · Accepted solution]

If I read the guideline as "owned foreign property at any time in the year with a total cost of more than CAN$100,000", I interpret the definition to be cumulative during the entire year. This would require the reporting of your Specified Foreign Property based on it's aggregate cost over the entire year for the periods of ownership.

I acknowledge that CRA does not specifically include this in their descriptions of qualifying reporting but this is as close as they come to it on their web site FAQ.

10. Assume that in 2013 I held shares in a non-resident corporation with a cost amount of $75,000 and, at the same time, I had a bank account in the U.S. with $35,000 on deposit. Am I exempt from filing Form T1135 since neither of the foreign properties has a cost amount greater than $100,000?

No. You must file Form T1135 since the total cost amount of all specified foreign property exceeds the $100,000 threshold ($75,000 + $35,000 = $110,000).

11. Assume I held specified foreign property during the year with a cost amount of more than $100,000, but held less than $100,000 at the end of the year (or no longer held the property). Do I still have to file Form T1135?

Yes. As long as you met the reporting requirement threshold of $100,000 at any time in the year, you must report on Form T1135 all specified foreign properties held during the year, even if you sold any or all of the property before the end of the year.