Section 233.7

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.

Furthermore, assuming the $100,000 cost amount threshold was exceeded, having regard to the above specified foreign property and any other specified foreign property of the taxpayer, 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 again became a resident of Canada in a subsequent year, the individual would be required to file the form for that year of becoming a resident in Canada again.