CRA notes the 1st-time s. 233.7 exemption from filing a T1135 can be used only once

CRA confirmed that interest earned by a Canadian resident on various types of accounts that were tax exempt or tax advantaged under French tax law would be included in computing the resident's income under the s. 12 rules, given the absence of any exemption under the Canada-France Income Tax Convention. The referenced accounts were the "livret jeune" (youth savings accounts), "livret bleu" (blue savings accounts), "livret de développement durable et solidaire" (sustainable and solidarity-based savings accounts) ("LDDS"), "compte épargne logement" ( home savings accounts) ("CEL"), and "compte capital expansion" (capital expansion accounts).

Furthermore, assuming the $100,000 cost amount threshold was exceeded, the taxpayer would be required to annually report such accounts in a T1135 form - except that, pursuant to s. 233.7, if the individual first became resident in Canada in a year, the individual was not required to provide the Form T1135 for that first year, notwithstanding s. 233.3. However, if the individual emigrated but then again became a resident of Canada in a subsequent year, the individual would be required to file the form for that subsequent year.

Neal Armstrong. Summaries of 22 August 2025 External T.I. 2021-0904251E5 F under s. 12(1)(c) and s. 233.7.