10 June 2013 STEP Roundtable, 2013-0485761C6 - 2013 STEP CRA Roundtable Question 3 -- summary under Subsection 233.3(3)

The extension of the normal reassessment period under draft s. 152(4)(b.2) - where (a) there has been a failure to file the T1135 as and when required or to provide therein the required information in respect of a specified foreign property, and (b) to to report an amount, in respect of a specified foreign property, that is required to be included in the taxpayer's income - applies for all purposes and not just to income derived from the unreported foreign assets.

U.S. shares or U.S. bonds held in a U.K. brokerage account should be coded as U.S. as "it is the residence of the corporation that issued the shares or the residence of the bond issuer that is relevant… ." Where there are gains and Canadian losses, only the foreign gains are reported on the T1135.

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