CRA confirms that no T1135 filing is required of a non-resident portion trust (or by a particular trust not holding foreign property)

S. 94(3)(f) provides for an election which effectively permits a (s. 94) deemed non-resident trust to elect to bifurcate itself into a “non-resident portion” trust (in broad-brush terms, holding property that has not been contributed by current or former residents of Canada) and the “particular trust” (holding the tainted property). CRA considers that neither of these two deemed subtrusts is required to report foreign property on T1135s provided that all the foreign property is held in the non-resident portion trust rather than the particular trust.

Neal Armstrong. Summary of 27 June 2016 T.I. 2014-0532601E5 under s. 94(3)(f).