Information returns relating to foreign affiliates

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Information returns relating to foreign affiliates for tax years beginning before 2021 (T1134 Version 2012/2017)

Note: The following information pertains to T1134 Version 2012/2017. For tax years that begin after 2020, refer to T1134 Version 2021 for guidance.

Do you have to file a return?

Form T1134 consists of a summary and supplements. A separate supplement must be filed for each foreign affiliate (non-resident corporation or non-resident trust) of the taxpayer or partnership that is at any time in the year either of the following:

Only the lowest-tiered Canadian corporation has to report on its foreign affiliate. For example, if Canco 1 owns 100% of the shares of Canco 2 and if Canco 2 owns 100% of the shares of Foreignco 1, only Canco 2 has to report, even though Foreignco 1 is a foreign affiliate of Canco 1.

A non-resident trust that is considered to be resident under section 94 of the Income Tax Act for purposes of Part I (discretionary trust) is also considered resident for purposes of the foreign affiliate reporting rules. As a result, such a trust may have to file Form T1134.

What has to be reported?

The required information is described in detail on Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates for tax years beginning before 2021 (T1134 Version 2012/2017):

Filing deadline

The applicable form is due within 15 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

Note

For tax years that begin in 2020, Form T1134 must be filed within 12 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period. For tax years that begin after 2020, the 2021 version of the Form T1134 must be filed within 10 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

Can I EFILE this form?

As of October 21, 2019, corporations and partnerships can attach supporting documentation, such as financial statements related to Foreign Reporting Returns submitted through EFILE, via your tax preparation software with the Submit electronic documents service.

By filing electronically, you will receive a confirmation number at once to tell you that the Canada Revenue Agency (CRA) has received your form(s).

For paper filers, please send the original return, amended return, or any additional information to the address provided on the back of the form. See the instructions in the Amending a T1134 return section.

For reporting entities that are individuals and trusts, a paper copy of this form must be filed separately from your income tax return.

Amending a T1134 return

Amendments include any changes to information previously provided on a summary or a supplement, the cancellation of any supplement(s) previously filed, and the addition of any new supplement(s) omitted from the original filing.

If you have paper-filed your T1134 return, any amendments necessary to any information contained in the summary or in the supplements of the T1134 return will require a resubmission of the entire paper filing. DO NOT E-file amendments to paper-filed returns. Clearly identify the nature of the amendment by writing "AMENDED", "CANCELLED", or "ADDITIONAL" as appropriate at the top of each summary or supplement being amended. Alternatively, you may detail the amendments required in a cover letter to accompany the summary or supplement(s) that are being amended.

If you have filed your T1134 return electronically, any amendments necessary to any information contained in the summary or the supplements of the T1134 return should also be submitted electronically. However, if you choose to amend your T1134 return by paper, you must detail the amendments required in a cover letter and follow the instructions for paper filers as described above.

Administrative policies

Do not file Form T1134 if the total cost amount to the reporting entity at any time in the year of the interest in all foreign affiliates was less than $100,000 and the foreign affiliate is dormant or inactive for the affiliate's tax year ending in your tax year.

The threshold for a dormant or inactive foreign affiliate (for which reporting is not required) has been raised. The threshold is changed from "less than $10,000 gross receipts, and assets with a total fair market value of no more than $100,000" to "less than $25,000 gross receipts, and assets with a total fair market value of no more than $1,000,000". This will reduce the number of foreign affiliates for which reporting is required.

Reporting on the organizational structure (Part I, Section 3)

If you are reporting on one or more controlled foreign affiliates, Part I, Section 3 requires you to produce information on the organizational structure once for a group of persons that are related to each other. Enter this information into the specific data fields.

Administrative relief

Administrative relief from reporting is provided for short tax years, for example, where there is a deemed year-end due to a change of control. Reporting for the normal 12 month tax year or fiscal period will be sufficient if the information that would otherwise be reported for the short tax year or fiscal period, for example, less than 12 months, is included on the T1134 return that is filed for the normal year-end. A separate filing for the short tax year is not required. This is consistent with the policy that has been in place for Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

We understand that if you are reporting on a tiered structure of foreign affiliates in this new format, area B of Section 3 would require you to complete several lines of repetitive information. To reduce this filing burden, the CRA will accept information limited only to each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity.

If the foreign affiliate of the reporting entity does not have a direct equity percentage in another foreign affiliate of the reporting entity, but does have an equity percentage, you are not required to provide information regarding this situation in area B of Section 3.

In summary, when completing Part I, Section 3B, list the name and country code of the country of residence of each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. Include the foreign affiliate's equity percentage and direct equity percentage in the other foreign affiliate.

Information returns relating to foreign affiliates for tax years beginning in 2021 or later (T1134 Version 2021)

Note: The following information pertains to T1134 Version 2021. For tax years that begin before 2021, refer to T1134 Version 2012/2017 for guidance.

Do you have to file a return?

Form T1134 consists of a summary and supplements. A separate supplement must be filed for each foreign affiliate (non-resident corporation or non-resident trust) of the taxpayer or partnership that is at any time in the year either of the following:

Only the lowest-tiered Canadian corporation has to report on its foreign affiliate. For example, if Canco 1 owns 100% of the shares of Canco 2 and if Canco 2 owns 100% of the shares of Foreignco 1, only Canco 2 has to report, even though Foreignco 1 is a foreign affiliate of Canco 1.

A non-resident trust that is considered to be resident under section 94 of the Income Tax Act for purposes of Part I (discretionary trust) is also considered resident for purposes of the foreign-affiliate reporting rules. As a result, such a trust may have to file Form T1134.

What's New for T1134 Version 2021?

The form's name was updated to T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates as opposed to the use of Not-Controlled Foreign Affiliates in prior versions.

The 2021 version of the Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates introduces a number of changes in the required information. A detailed description of the information required can be found on the form, some of the key changes are highlighted in the following paragraphs. 

What has to be reported?

The required information is described in detail on Form T1134, Information Return Relating to Controlled and Non-Controlled Foreign Affiliates for tax years beginning in 2021 or later (T1134 Version 2021):

Filing deadline

For tax years that begin in 2020, Form T1134 must be filed within 12 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period. For tax years that begin after 2020, Form T1134 must be filed within 10 months of the end of the reporting taxpayer's tax year or, in the case of a partnership, fiscal period.

For taxation years or fiscal periods that began before 2021, please use the previous 2012/2017 version of the Form T1134 as released on November 28, 2017. 

Can I EFILE this form?

As of October 21, 2019, corporations and partnerships can attach supporting documentation, such as financial statements related to Foreign Reporting Returns submitted through EFILE, via your tax preparation software with the Submit electronic documents service.

By filing electronically, you will receive a confirmation number at once to tell you that the Canada Revenue Agency (CRA) has received your form(s).

For paper filers, please send the original return, amended return, or any additional information to the address provided on the back of the form.

For reporting entities that are individuals and trusts, a paper copy of this form must be filed separately from your income tax return.

Individuals can EFILE and NETFILE the T1134 forms electronically for the 2021 and later taxation years as of February 7, 2022.

In the future, the CRA will make the electronic filing of Form T1134 available for Trusts and will announce when the service becomes available.

Amending a T1134 return

Amendments include any changes to information previously provided on a summary or a supplement, the cancellation of any supplement(s) previously filed, and the addition of any new supplement(s) omitted from the original filing.

Once you have filed your T1134 return for a taxation year, either as a group of related reporting entities or as one reporting entity, the filing option so adopted will remain for that taxation year.

If you have paper-filed your T1134 return, any amendments necessary to any information contained in the summary or in the supplements of the T1134 return will require a resubmission of the entire paper filing. DO NOT E-file amendments to paper-filed returns. Clearly identify the nature of the amendment by writing "AMENDED", "CANCELLED", or "ADDITIONAL" as appropriate at the top of each summary or supplement being amended. Alternatively, you may detail the amendments required in a cover letter to accompany the summary or supplement(s) that are being amended.

If you have filed your T1134 return electronically, any amendments necessary to any information contained in the summary or the supplements of the T1134 return should also be submitted electronically. However, if you choose to amend your T1134 return by paper, you must detail the amendments required in a cover letter and follow the instructions for paper filers as described above.

Administrative policies

For tax years or fiscal periods that begin after 2020, the criteria to qualify for the exemption from filing the T1134 supplement for "dormant" or "inactive" foreign affiliate has been revised and will be applied at the individual legal entity level. Do not file Form T1134 Supplement in respect of a foreign affiliate if the total cost amount to the reporting entity at any time in the year of the interest in that foreign affiliate was less than CAD $100,000 and that foreign affiliate is "dormant" or "inactive" for the affiliate's taxation year ending in your taxation year. Where a group of related reporting entities are electing to file under the group filing option, each reporting entity within the related group is required to determine whether a foreign affiliate meets the criteria to be considered as a "dormant" affiliate for the reporting period based on that reporting entity's total cost amount in that foreign affiliate. Unless each member of the related Canadian group meets the less than CAD $100,000 threshold for the total cost amount in that foreign affiliate, a separate T1134 Supplement will need to be filed in respect of that foreign affiliate.

The threshold for a dormant or inactive foreign affiliate (for which reporting is not required) has been raised for tax years that begin after 2020. The threshold is changed from "less than $25,000 gross receipts, and assets with a total fair market value of no more than $1,000,000" to "less than $100,000 gross receipts, and assets with a total fair market value of no more than $1,000,000". This will reduce the number of foreign affiliates for which reporting is required.

Administrative relief

Administrative relief from reporting is provided for short tax years, for example, where there is a deemed year-end due to a change of control. Reporting for the normal 12 month tax year or fiscal period will be sufficient if the information that would otherwise be reported for the short tax year or fiscal period, for example, less than 12 months, is included on the T1134 return that is filed for the normal year-end. A separate filing for the short tax year is not required. This is consistent with the policy that has been in place for Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents.

For tax years or fiscal periods that begin after 2020, there is an option to electronically submit a pictorial of the organizational chart which will significantly reduce the filing burden if you are reporting on a tiered structure of foreign affiliates in the T1134 Summary, Part I, Section 3, C. Organizational Chart, Tables i) through iv).

If you choose to fill out Part I, Section 3, C. Organizational chart, instead of providing the organizational chart in pictorial format, the CRA will accept information limited only to each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. If the foreign affiliate of the reporting entity does not have a direct equity percentage in another foreign affiliate of the reporting entity, but does have an equity percentage, you are not required to provide information regarding this situation in Part I, Section 3, C. Organizational chart, table (ii). In summary, when completing Part I, Section 3.C. table (ii), list the name and country code of the country of residence of each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. Include the foreign affiliate's equity percentage and direct equity percentage in the other foreign affiliate.

However, the CRA will no longer allow one reporting entity within a related group to report the information required in Part I, Section 3, C. Organizational chart on behalf of the group; that is, if the related Canadian group chooses not to take advantage of the group filing option.

Forms and Publications

You can access both the 2012/2017 version of the T1134 for tax years beginning before 2021, and the 2021 version of the T1134 for tax years beginning in 2021 or later by viewing T1134 Information Return Relating To Controlled and Non-Controlled Foreign Affiliates page.

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