A taxpayer is required to file a form T1135 in respect of foreign property, including foreign securities, even if the securities are held in a Canadian brokerage account. If you fail to file the form in these circumstances, and the CRA imposes penalties, good luck on a relief application. Even if all of the income derived from these investments has been scrupulously reported, neither the CRA nor the Federal Court is likely to be sympathetic apparently. See David Asper Holdings Inc. v. Canada (Attorney General), 2010 FC 896.
The FCA has dismissed the taxpayer’s appeal: see 2011 FCA 299.