An Australian Superannuation Fund (or “Super Fund”) is a government-regulated trust that has been registered and approved by the Australian Government and is funded by contributions from employers and individuals over their working lives in order to provide retirement incomes. After concluding that a Canadian beneficiary’s interest is considered to be specified foreign property, and the individual is required to file T1135s reporting inter alia the “cost amount” of the individual’s interest in the fund, CRA stated:
Provided the Super Fund described above is a pension and an employee benefit plan, the cost amount of the interest in the Super Fund will be the amount the individual has a right to receive in respect of the Super Fund. This includes all amounts to which the individual has a legal right to receive, even if the amounts are to be received in the future.
...[W]here it is not possible to determine the cost amount of a specified foreign property, taxpayers should use their best efforts to reasonably estimate the cost amount... .