September 6, 2026

T1135 and Offshore Casino Wallets: When Do You Have to Report?

In this article
  1. What Form T1135 Actually Requires
  2. Is Crypto "Foreign Property" at All? The CRA's View
  3. The Casino Balance Problem
  4. Counting to $100,000: a Quick Reality Check
  5. What to Actually Do

What Form T1135 Actually Requires

Form T1135, the Foreign Income Verification Statement, must be filed by Canadian residents who hold specified foreign property with a total cost amount above CAD $100,000 at any point in the year. Two details matter more than anything else:

  • The threshold is measured by cost (essentially your adjusted cost base), not market value. Coins bought at $60,000 that mooned to $150,000 are still $60,000 for T1135 purposes.
  • It is "at any time in the year" — a two-week spike over the line triggers the filing even if you ended the year at zero.
  • The penalty for not filing is $25 per day, up to $2,500 per year, and it applies even if you owed no tax at all.
  • The form is separate from reporting the gains themselves — those go on Schedule 3 either way.

Is Crypto "Foreign Property" at All? The CRA's View

The CRA generally treats cryptocurrency as funds or intangible property, and has indicated that crypto can be specified foreign property when it is situated, deposited or held outside Canada. The genuinely unsettled question is where a decentralized asset is "situated." The most common professional reading splits it this way:

  • Coins on a foreign exchange or platform — the platform holds them, the platform is offshore, so they count toward the $100,000. This is the position most practitioners apply.
  • Coins in your own self-custody wallet — much harder to call "situated" anywhere. Positions differ; some argue keys held in Canada mean the property is in Canada, but this is not something the CRA has definitively blessed.

Nothing here is fully settled law. What is clear is the direction: the CRA has been expanding visibility into crypto, not shrinking it, and the safest reading is to count foreign-platform crypto toward the threshold.

The Casino Balance Problem

Now the awkward case this article exists for: crypto sitting in your account at an offshore casino — a Curaçao or Anjouan-licensed site with no Canadian presence. Once deposited, you usually don't hold coins at all; you hold a claim against a foreign operator, a balance the casino owes you. An interest in or right to property held by a non-resident is squarely the kind of thing T1135 was written to capture, so a large standing balance at an offshore casino is hard to wave away.

There is a counter-argument — that a gambling balance is a personal-use arrangement rather than an investment property — but it is untested, and betting a $2,500 penalty on an untested argument is poor odds. The safest reading: if your casino balances plus other foreign-held crypto ever exceed $100,000 of cost in a year, file. The practical fix is simpler than the legal question: don't park winnings at the casino. Withdraw after every session — the operators in our ranking pay out in minutes, and our instant-withdrawal category exists precisely so a balance never has to sleep offshore.

Counting to $100,000: a Quick Reality Check

Because the threshold uses cost amount, your ACB records do double duty here. Example: you hold USDT with an ACB of $70,000 on a foreign exchange, keep a running $20,000 balance at an offshore casino, and briefly move another $15,000 there for a high-roller weekend. At that moment your foreign cost amount is $105,000 — the T1135 obligation is triggered for the year, even though no single account ever looked scary. Winnings left on-site count too, at their value when won, which is another reason the withdraw-every-session habit from our ACB tracking guide pays for itself.

What to Actually Do

If you are near the line: pull your ACB by platform, check the year's high-water mark, and when in doubt file — T1135 costs nothing to submit and $2,500 to skip. If you should have filed in past years and didn't, don't just start filing silently; ask a professional about the Voluntary Disclosures Program first, because a quiet first-time T1135 can itself flag the earlier gap. And keep per-platform records even at no-KYC casinos — the form asks where property is held, and "I don't know" is not an answer the CRA accepts.

This article is general information, not tax advice — T1135 and crypto is one of the most contested corners of Canadian tax right now. For your own situation, engage a licensed CPA before you file, not after.

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