Form T1134A, Information Return Relating to Foreign Affiliates that are not Controlled Foreign Affiliates, and Form T1134B, Information Return Relating to Controlled Foreign Affiliates, have been combined to form Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates.

Administrative Policies

The new Form T1134 is in Summary and Supplement format. A summary must be completed for each reporting entity. A separate supplement must be completed for every foreign affiliate and controlled foreign affiliate of which is being reported.

The threshold for which reporting is not required has been raised to include situations where the total cost amount to the reporting entity at any time in the year of the interest in all foreign affiliates was less than $100,000.

Reporting on the organizational structure (Part I, Section 3)

If you are reporting on one or more controlled foreign affiliates, Part I, Section 3 requires you to produce information on the organizational structure once for a group of persons that are related to each other. Under the old version of the form (T1134B), you were able to satisfy this requirement by submitting a group organizational chart that included the requested information. Now, Part I, Section 3 of the new T1134 requires you to enter information of the group organizational structure into specific data fields.

Administrative relief

We understand that if you are reporting on a tiered structure of foreign affiliates in this new format, area B of Section 3 would require you to complete several lines of repetitive information. To reduce this filing burden, the CRA will accept information limited only to each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity.

If the foreign affiliate of the reporting entity does not have a direct equity percentage in another foreign affiliate of the reporting entity, but does have an equity percentage, you are not required to provide information in this situation in area B of Section 3.

In summary, when completing Part I, Section 3B, list the name and country code of the country of residence of each foreign affiliate of the reporting entity that has a direct equity percentage in any other foreign affiliate of the reporting entity. Include the foreign affiliate's equity percentage and direct equity percentage in the other foreign affiliate.

Items eliminated from the forms

• The Summary/Supplement format has eliminated substantial duplication of information regarding the reporting entity.

• The tick box for "From 6 to 15 employee or employee equivalents" (Part III, Section 1).

Item added to Form T1134

• A 3-character space at the top of the Summary sheet to indicate the functional currency code if an election has been made to use a functional currency.

• A space to include a business number of the reporting entity if they have another BN for other reporting purposes (Part I, Section 1).

• A 3-character space to report the country code of the reporting entity (Part I, Section 1).

• A question regarding short taxation years (Part I, Section 1).

• A space to provide the number of Supplements attached to the Summary sheet (Part I, Section 1).

• A tick box for the answer "no" to the question of whether the corporation ceased to be a foreign affiliate of the reporting entity in the year (Part II, Section 2).

• A question on whether the foreign affiliate is a controlled foreign affiliate (Part II, Section 2).

• A 3-character space for a currency code of the amount reported (Part II, Section 4).

Format changes

• Reporting on the Organizational Structure, which is required only if you are reporting on one or more controlled foreign affiliates has been modified to include the information on the form. The option to submit a group organizational chart has been removed (Part I, Section 3). Refer to the administrative policies above for additional information.

• Surplus accounts of the foreign affiliate has been revised to remove tick the box surplus pools and to include a specific amount of dividend received from each surplus pool (Part II, Section 4).

• Tick box gross revenue ranges have been replaced with actual amounts and currency codes (Part III, Section 2).

• All NAICS codes have been revised to include all 6 digits.

• All amounts are to be stated in Canadian dollars or in the elected functional currency where they are available for Canadian income tax reporting purposes. Where amounts may only be available from the books and records of the foreign affiliate, a space has been provided to include the 3-character currency code in which the amounts are reported.

Date effective

The changes are effective for tax years and fiscal periods that start after 2010.

Forms and publications

• Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates
• Form T106, Information Return of Non-Arm's Length Transactions with Non-Residents