Does the CRA Require Foreign Pension Holdings to be Disclosed? (i.e., Information Disclosed in My Annual Foreign Income Verification Statement - Form T1135)

[jclogs]

Hello All, 

I am hoping that someone here has direct knowledge or some experience with the CRA's foreign pension reporting requirements.  

I am looking to confirm that the CRA does NOT require individuals to disclose their foreign pension holdings annually using Form T1135 - Foreign Income Verification Statement.  

After I spent time to try and clarify the CRA's requirements, I was only able to find one online article/blog post stating that foreign pensions are exempt from the CRA's reporting requirements.    I was hoping to have this confirmed to gain a bit more comfort that I am not at risk of incurring the fines for not reporting.  

Thanks in advance for your help!

J

HERE IS SOME ADDITIONAL BACKGROUND

While working abroad in both the USA and the UK I became a non-resident of Canada for tax purposes.  While outside of Canada, I contributed to my employer's local pension plans.  These contributions were more than the Canadian equivalent of C$250,000 in each pension plan (i.e., > C$500k total).   

Now that I am back in Canada (i.e., a resident in Canada for tax purposes), I had assumed the CRA would want me to report these holdings.  However, I was having trouble completing Form T1135 as it did not seem applicable, which led me to further research the CRA's reporting requirements.   

After spending some time, I found only one reference on the following website/blog:

Foreign reporting and the foreign pension plan - All About Estates

The author stated the following.....

1. "The foreign property reporting rules are in section 233.3 of the Income Tax Act (ITA)."

2. "Generally, these rules require certain taxpayers resident in Canada and certain partnerships to file an information return (Form T1135) with respect to their “specified foreign property” if the total cost amount of such property exceeds $100,000."

3. "Specified foreign property is broadly defined in ITA 233.3(1) but is subject to a number of exceptions."

4. "One of these exceptions is for an interest in a trust that is established in connection with a foreign plan that provides pension, retirement or employee benefits where the trust is exempt from income tax imposed by the country of its residence and is maintained primarily for the benefit of non-resident individuals. 

These exemptions seem to be applicable in my situation.  As I am sure not the only person in Canada with foreign pension holdings I was hoping to confirm as I have only found one reference.  

[TurboTaxSusan]

No, generally you don’t have to report foreign pension holdings.

But it would still be a good idea to contact the Canada Revenue Agency (CRA) and check with them. If you are in Canada or the United States, you can call the CRA at 1-800-959-8281.