Shares in a Foreign Company: When Do You File the T1134?

Who has to file, what to report, and how it differs from the T1135

Scott Tang, CPAUpdated 2026-11-052026 rules4 min read

You set up a company in mainland China or Hong Kong before you immigrated, and you still hold the shares after the move — that company is quite likely your foreign affiliate, and you have to file a T1134 for it every year. The T1134 and the T1135 are two different forms: the T1135 reports ordinary foreign assets; the T1134 reports foreign companies in which you hold a certain stake.

1% · 10%

If your equity percentage (direct plus applicable indirect) is at least 1%, and you and related persons together hold at least 10%, the company may be a foreign affiliate

10 months

Due within 10 months after the end of the tax year; for individuals, usually October 31 of the following year

One per company

A separate form for each foreign affiliate (dormant companies are excepted under certain conditions)

$25 a day

Late-filing penalty, minimum $100, maximum $2,500; heavier if the failure is knowing or due to gross negligence

How the T1134 and the T1135 differ

Item	T1135 foreign property	T1134 foreign affiliates
What it reports	Deposits, shares, rental properties and other ordinary foreign assets	Foreign companies in which you hold a certain stake
Threshold	Total cost of more than C$100,000	Your equity percentage is at least 1%, and at least 10% together with related persons
When it's due	With your tax return (April 30 for individuals)	10 months after the end of the tax year
What you fill in	Asset category, country, cost, income	Corporate structure, shareholdings, financial data, nature of the business
Any double reporting?	Shares of a foreign affiliate don't go on the T1135	Reported only on the T1134

If it's "controlled", look at passive income too

If the shares held by you, your related persons (spouse, parents, children, siblings and so on, wherever they live), and up to four other Canadian-resident shareholders (related to you or not) and their related persons together give control of the foreign company, it is a "controlled foreign affiliate". Its passive income (interest, rent, investment income and so on — together called foreign accrual property income, or FAPI) has to be included in your Canadian income every year, even if the company pays no dividends.

Your company in China runs a real business

Has staff and operations

Active business income

Generally not included in your income year by year

Reported when dividends are paid to you

Your company in China only holds assets

Deposits, a rental property, wealth-management products

Passive income (FAPI)

Included in your income every year, in proportion to your shareholding

You may have to report it even if no dividends are paid; FAPI is adjusted for items such as foreign accrual tax. This is what newcomers most often overlook

What you report, in outline

1
Structure
Company name, country, percentage of shares held
2
Related persons
Family members and related companies that hold shares with you
3
Business
Main business, number of employees
4
Financials
Revenue, profit, assets, income tax paid
5
If controlled
Also report surplus accounts and passive income

Points to watch

Look at it when you land
For company shares you held before landing, your cost is their fair market value on the day you became a resident, and from that day the company may be a foreign affiliate. In the year an individual first becomes a Canadian resident, there is a filing exception for the T1134, but that doesn't remove the need to work out that year's income (including FAPI).
Family holdings are added together
Shares held by your spouse, parents, brothers and sisters count together toward the 10%, so you may have to file even if your own stake is small.
You need the company's financial data
The T1134 calls for financial statements and tax returns, so talk to the company's finance and accounting staff in China early.
Haven't filed before?
For years you missed, you can consider a voluntary disclosure; see "Unreported Foreign Income from Past Years? The Voluntary Disclosures Program" in this series.

How Sheng Qian CPA can help

First, whether you need to file
Based on your and your family's shareholdings, we look at which companies are foreign affiliates and whether they are controlled.
Calculating passive income
For controlled affiliates, we work out in advance whether there is FAPI and how much has to be included each year.
Working with the finance team in China
We list the statements and data the company in China needs to provide, and complete the T1134 on time; for fees, see "What Sheng Qian CPA Can Do for Cross-Border Families: From Tax Returns to Foreign Asset Reporting" in this series.

Sources

CRA: Form T1134 and guidance · Foreign reporting
CRA: Questions and answers about penalties

Disclaimer

This article is general information only and is not tax advice. Everyone's situation is different; please consult a CPA about your specific arrangements. Service fees are as set out in our written quote.