Behind the Form: T1134 for Non-Specialists
Learn the rules, then watch a completed T1134 filled in section by section. Built for practitioners who file without an international tax background.
The T1134 Is One of the Most Confusing Forms in Tax Practice
The form points you to the Income Tax Act at almost every turn, yet much of it will not apply to your file. The hard part is knowing which parts do. This two-part live program shows non-specialists what the key terms mean, how to complete the form accurately, and where to spot the issues that call for help.
Is This Program for You?
If any of these describe a file on your desk, this program was built for you.
- check_circleA client owns shares of a foreign corporation, directly or through a holding company
- check_circleA client holds an interest in a US LLC or LLLP
- check_circleRelated non-residents also own shares of the same foreign corporation
- check_circleA foreign corporation has lent money to a Canadian corporation
- check_circleYou are unsure whether an entity belongs on the T1134 or the T1135
- check_circleYou prepare T1134s every year and want a refresher on what changed
The form is unchanged from 2025, but the law behind it is not. The material covers the new FABI regime and its elections for CCPCs and SCCPCs, the new purpose test for tracking interests, and updated CCPC illustrations.
Two Sessions, One Program
Part 1 builds the concepts. Part 2 applies them to a completed form. Each session runs 90 minutes, followed by about 30 minutes of live Q&A with both presenters.
Concepts, Definitions and Rules
- check_circleWho must file, and when the form is due
- check_circleForeign affiliates, equity percentage and control
- check_circleHow FAPI is calculated, including the new FABI rules
- check_circleSurplus pools, dividends and upstream loans
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- How the form got here. Announced in the 1995 budget, law in 1997, updated in 2011 and significantly expanded for years beginning after 2020. Organizational structure diagrams are accepted again.
- Who must file. Canadian residents with an FA or CFA at any time in the year, including deemed resident trusts and certain partnerships. First-time resident individuals are exempt in their year of immigration; returning residents are not.
- Due date and missing information. 10 months after the reporting entity's year-end. Attach financial statements and flag gaps in Part IV. CRA may void a form missing substantial information.
- Foreign affiliate. A corporation for Canadian purposes, resident outside Canada under mind and management, meeting the 1% and 10% equity percentage tests.
- Equity percentage. Direct plus indirect ownership, using the share class with the highest percentage.
- Controlled foreign affiliate. De jure control, the group-of-four rule, and how non-arm's length owners anywhere in the world can create CFA status.
- Entities with no shares. The s. 93.2 deeming rule for US LLCs and LLLPs, with a worked example.
- What counts as FAPI, including income deemed FAPI under s. 95(2)(a.1) and (b), and the main exclusions.
- FAT and the relevant tax factor. A grossed-up s. 91(4) deduction, not a foreign tax credit: 1.9 for individuals, trusts, CCPCs and SCCPCs; 4.0 for public and non-resident controlled corporations.
- FABINew for tax years beginning after 2025: how it is carved out of FAPI, the base erosion tests, and the election for a 4.0 factor.
- Cost base, double tax and FAPI losses. How net FAPI moves the ACB of CFA shares, and why losses only offset FAPI of the same CFA.
- Surplus pools. Exempt, hybrid, taxable (including FABI surplus) and pre-acquisition, with the ordering rules and elections.
- Dividends to a Canadian corporation. How s. 113 deductions work and which pools feed GRIP or CDA.
- Upstream loans and the 24-month repayment exception, plus the s. 93(1) election.
- Tracking interestsNew and the purpose test added in the 2025 budget; FA dumping, QLAD and QROC at a high level.
Case Study: A Completed T1134 with Commentary
A Canadian corporation with three foreign affiliates, a loan, a dividend and year-ends that do not line up. Modest facts, but they raise a surprising number of questions. Michael and Matthew complete the form on screen and explain what each question is really asking.
- check_circleScoping the file with an org chart first
- check_circleA worked FAPI calculation under Canadian rules
- check_circleEach section of the Summary and Supplements
- check_circleThe traps, and what to flag when information is missing
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- Scope the file. Which entities are FAs, CFAs or dormant, and how many supplements you need.
- Work out the FAPI first. Under Canadian rules, including foreign depreciation and the s. 91(4) deduction.
- Identify the reporting entity. Currency, amendments, related group filing, short years and who signs.
- The rollover questions. Sections 85 to 88, drafted more broadly than most preparers assume.
- The organizational structure tables, and the dormancy question worded as a double negative.
- Dormant and lower-tier affiliates. What each still requires.
- A supplement for a CFA. Shares, ACB, equity percentage, debt and its T106 counterpart.
- ACB, surplus and dividends, and whose taxation year governs the timing.
- The upstream loan questions. Three linked answers for a repaid loan.
- Financial statements and FAPI reporting, so your form and your T2 agree.
- A non-controlled affiliate and Part IV. How much is skipped, and how to flag missing information.
- Practical conclusions. What to track early and when to call for specialist help.
Learn Live from Tax Experts
Both presenters lead the sessions and take your questions live.
Managing partner at Cadesky Tax and a contributor to the profession since 1980. Past governor of the Canadian Tax Foundation, past chair of STEP Canada and STEP Worldwide, and co-author of 11 books on tax.
Guides individuals, high-net-worth families and foreign corporations through Canadian tax, with practical, no-fluff solutions that work for his clients.
Frequently Asked Questions
When are the sessions?expand_more
Part 1 runs Wednesday, October 7, 2026 and Part 2 runs Tuesday, October 13, 2026, both at 12:00 PM ET. Each session runs 90 minutes, followed by about 30 minutes of live Q&A.
Do I need to attend both sessions?expand_more
The two sessions are designed as one program. Part 1 builds the concepts that Part 2 applies to a completed form. One registration covers both.
What if I miss a session?expand_more
Session recordings are included with registration, so you can catch up on anything you miss.
Do I need an international tax background?expand_more
No. The program is for CPAs and non-specialists who prepare T1134s or advise clients with foreign corporations. It assumes general accounting knowledge only, and runs every October as a refresher for repeat filers.
Has the form changed for 2026?expand_more
The form is unaltered from 2025. The legislation behind it has changed, in particular the FABI regime for CCPCs and SCCPCs and the purpose test for tracking interests. The material is updated for both.
What is included with registration?expand_more
Both live sessions with Q&A, recordings, detailed notes, the completed case study form, a sample client engagement letter and reference materials, with one year of access from registration.
Two live sessions, a completed form walked through line by line, and answers to your questions from the presenters.