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How do I report my US-listed Vanguard ETFs on Form T1135?

April 8, 2015 - 12 comments

With the 2014 tax deadline looming, this is becoming a very common question from DIY investors. Although there are still a number of uncertainties with regards to filling out the form, an investor with a relatively straight-forward situation should be able to muddle along for now.

Step 1: Determine if Form T1135 applies to your situation

If your US-listed Vanguard ETFs had a total cost base of at least $100,000 in Canadian dollars at any time during the 2014 tax year, you need to file Form T1135. Please do not rely on the cost base that your brokerage provides you with (for more information on the errors that your brokerage may be making, please read my recent post, Book Value Blunders).  

If you need more information on how to track the cost base of your US-listed ETFS in Canadian dollars, please refer to Calculating Adjusted Cost Base when Purchasing Foreign Currency Securities, at Adjusted Cost

Step 2:  Calculate your realized gains and losses on your US-listed ETFs

Once you have determined that you are required to file Form T1135, you will also need to calculate any gains and losses realized on the sale of your US-listed ETFs during the 2014 tax year. Regardless of whether you have to file Form T1135, you still need to report these amounts, so hopefully you have been keeping accurate records.

If this is not the case, please refer to our white paper, As Easy as ACB. In the paper, we recommend using the free online resource, Adjusted Cost, in order to keep track of your gains and losses for tax purposes.

Step 3:  Download the T1135 Worksheet (2014)

By clicking on the link below, you will be able to download the T1135 Worksheet for 2014. Any areas in light blue can be filled in by you (all other cells have been protected and should not be tampered with).


Download T1135 Worksheet (2014)

T1135 Worksheet (Sample): 2014

Sources: Canadian Portfolio Manager Blog, Bank of Canada

Step 4:  Enter the total fair market value of your US-listed ETFs at each month-end

Using your month-end brokerage statements, tally up the market value of your US-listed ETFs in US dollars. In the example below, the investor held two US-listed ETFs with a total market value in US dollars of $244,451.70. Enter these amounts into the Fair market value (USD) column

Note: If your brokerage statements display the market value of your US-listed ETFs in Canadian dollars, do not use the provided spreadsheet; it is meant to convert US dollar market values into Canadian dollars using the average Bank of Canada exchange rate for the year.  

Fair Market Value (USD):  December 2014

Source: RBC Direct Investing

If you only receive quarterly statements, this can cause issues with obtaining the missing month-end values of your US-listed ETFs. The Investment Industry Association of Canada has asked CRA to address what an investor should do in this situation – so far there does not appear to be an answer. To be conservative, the investor may decide to estimate the fair market value by multiplying the number of shares held at month-end by the market value of the security at month-end (which is available on Vanguard’s website).

In the example below, the total fair market value in US dollars for the May 2014 month-end is estimated to be $246,492.25.

Estimated Fair Market Value: May 30, 2014

Source: The Vanguard Group

Step 5:  Enter the gross income (dividends) received into the worksheet

Using your monthly brokerage statements, look for any dividends received during the month (for Vanguard equity ETFs, these are generally paid quarterly). The dividends should be the gross amount (i.e. before foreign withholding taxes). Enter these amounts into the Income (USD) column.

Income (USD):  December 2014

Source: RBC Direct Investing

Once all of this information has been entered, the worksheet will calculate the following amounts in Canadian dollars that can then reported in section 7 of Form T1135:

  • Maximum fair market value during the year
  • Fair market value at year end
  • Income (loss)
By: Justin Bender with 12 comments.
  10/11/2017 10:59:35 AM
Justin bender
@Matthew: Correct – you would check off “Property held in an account with a Canadian registered securities dealer or a Canadian trust company”.
  04/11/2017 11:34:30 AM
This was a very useful article. If I have US listed securities held with TD direct investing of more than $100,000, but less than $250,000 it is my understanding I can use the simplified reporting method. Which type of property would I select for US stocks held with TD? Property held in an account with a CDN securities dealer? thank you.
  05/09/2017 1:47:00 PM
Justin Bender
@Mike: As long as the USD cash is held with a Canadian brokerage, you do not have to include it on the T1135 report.
  02/09/2017 2:43:09 PM
I hold US cash as well as US listed securities in my US margin account. Do I need to add the cash to the securities market value each month, or is it only the securities that I need to total?
  13/04/2017 10:31:53 AM
Justin Bender
@Matt: You're very welcome! :)
  12/04/2017 9:42:52 PM
@Justin - thanks so much!
  11/04/2017 2:57:21 PM
Justin Bender
@Matt: Our marketing director has now added a download button for the 2016 T1135 Worksheet in the blog post above.
  10/04/2017 9:45:05 PM
Is there an updated (2016) version of this? Tried to use it, but can't change the exchange rates. Looks like it would be helpful to use year to year. Thanks for considering.
  24/04/2015 2:52:08 PM
Justin Bender
@Dean - this is a result of the month-end values being converted at the average exchange rate for the year, and the year-end value being converted at the year-end exchange rate for the year. CRA was very specific that this is the way they would like the form filled out (even though it can seem a bit strange intuitively):
  23/04/2015 6:33:40 PM
In the given example, it appears the maximum fair market value is less than the year end market value (because of the higher year end exchange rate). Will CRA have an issue with this?

I ran into this on my own worksheet and was wondering if the year end value should be used for the maximum market value on the T1135.
  08/04/2015 4:15:49 PM
Justin Bender
@Lydia - you're very welcome.

The FMV at year-end (CAD) is the $244,451.70 USD amount from the December 2014 statement multiplied by the Bank of Canada closing exchange rate of 1.1601 at year-end.

VUN would not have to be reported on Form T1135, as it is a Canadian-domiciled ETF.
  08/04/2015 3:02:49 PM
Thank you for addressing this topic.
In your worksheet example I cannot determine where the FMV year end figure of $283,588.42 comes from.
Also, is it certain that VUN would not have to be reported?

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