AI agents for business finance: what they can and can't do
What AI agents can do in bookkeeping, close, collections and compliance today, where a person must stay in charge, and how to judge a product.
The short answer
Filing Form T1135 late costs C$25 a day for up to 100 days, so between C$100 and C$2,500 per return, and much more if the CRA finds the failure was knowing or grossly negligent (C$500 a month up to C$12,000, and further penalties after a demand or 24 months). If you have missed years, you can file now and ask for relief, or apply to the Voluntary Disclosures Program: since 1 October 2025, unprompted disclosures can get full penalty relief and 75% interest relief.
The penalties, from the CRA’s table
The CRA’s table of foreign reporting penalties, modified 20 October 2026, sets these for Form T1135:
| Situation | Penalty | Law |
|---|---|---|
| Late or not filed | C$25 a day, up to 100 days; minimum C$100, maximum C$2,500 | s.162(7) |
| Knowingly or through gross negligence not filed | C$500 a month, up to 24 months, maximum C$12,000, less penalties already charged | s.162(10)(a) |
| Not complying with a CRA demand to file, knowingly or through gross negligence | C$1,000 a month, up to 24 months, maximum C$24,000, less penalties already charged | s.162(10)(b) |
| Still not filed after 24 months under the above | Additional 5% of the cost of the foreign property, less penalties already charged | s.162(10.1) |
| False statement or omission, knowingly or through gross negligence | Greater of C$24,000 or 5% of the cost of the property | s.163(2.4) |
The table marks the due diligence exception as not available for T1135, so "I did not know" is not a defence to the basic penalty. Penalties apply per return, per year, whether or not any tax was owed. Separately, the T1135 questions and answers say the CRA gets an extra three years to reassess income from the property where T1135 was not filed, was late or was wrong.
Worked example: what is at stake
Example only. Ngozi has lived in Winnipeg since 2020. Her Nigerian savings, domiciliary account and land have been above C$100,000 in cost since 2022, and she has never filed T1135. If she files the three missing forms now, unprompted, the basic penalty for each could reach the C$2,500 maximum (C$25 × 100 days), so C$7,500 in all, before any relief. If the CRA wrote to her first and she ignored it, she would be in the far higher gross-negligence bands.
Route 1: file now and ask for relief
The T1135 questions and answers say the CRA may grant relief under the taxpayer relief provisions if you make a written request, using Form RC4288, Request for Taxpayer Relief. Each request is decided on its merits. This route suits someone with one late form and a clear explanation of why it was late.
Route 2: the Voluntary Disclosures Program
The CRA says the VDP may be available to T1135 filers who gave incomplete information, omitted information or did not file, as long as they make a valid disclosure. The programme changed for applications received on or after 1 October 2025, under Information Circular IC00-1R7:
- Unprompted disclosure (general relief)
- 100% penalty relief and 75% interest relief.
- Prompted disclosure (partial relief)
- Up to 100% penalty relief and 25% interest relief. A disclosure made after a CRA communication, such as an education letter, can now qualify.
- Still excluded
- People under audit or investigation, and those the CRA finds egregiously non-compliant.
- Years to include
- For foreign-sourced income or assets, the most recent 10 years with errors; years without errors can be left out.
- Form
- RC199, simplified in 2025, with all supporting returns, forms and schedules.
The application has to include the corrected documents, so prepare the T1135 forms, and amended returns for any unreported Nigerian interest, rent or gains, before you apply. Interest relief matters only where tax was owed; the penalty relief is the main prize for a pure T1135 failure.
What a valid application needs
The changes page says applications must include the supporting documents needed to correct the non-compliance: returns, forms, statements and schedules. For a T1135 case that means each missing T1135, completed with the maximum cost and year-end cost of every Nigerian account, plot or share holding, plus amended T1 returns where income was left out. Partial packages slow the review. The CRA may ask for documents for years earlier than the ten-year window. Keep copies of everything you send, and of the bank statements you used to rebuild the balances, because the review can take months.
Which route fits
- Only the form is missing, no income was left out, and you have a reason: file and request relief with RC4288.
- Several years missed, or Nigerian income also left off your returns: the VDP is usually the safer route, because it covers both.
- The CRA has already written to you: a prompted VDP application may still be possible; act quickly.
- You are under audit: the VDP is not open to you; get professional help.
Steps
- List every year you were resident and above C$100,000 in foreign property cost.
- Rebuild the highest balance and year-end figures for each Nigerian account, converted to Canadian dollars.
- Check whether interest, rent or gains were left off your returns.
- Decide between RC4288 and RC199, then file the complete package at once.
- From now on, diary T1135 with your return each April.
Where Pryme fits
Rebuilding past balances is the slow part of any disclosure. Going forward, keeping your money in a multicurrency account and generating verifiable statements with VerifyDoc.ai at each year end gives you the figures T1135 asks for. See also what counts for T1135.
Questions people ask
What is the penalty for filing T1135 late?
C$25 a day for up to 100 days, with a minimum of C$100 and a maximum of C$2,500 per form, under the CRA’s table of penalties. Higher penalties apply for knowing or grossly negligent failure.
Can the CRA waive the T1135 penalty?
It may, on a written request using Form RC4288. Each case is decided on its own merits.
Does the VDP cover T1135?
The CRA says it may, for people who omitted information or did not file. Unprompted applicants can get 100% penalty relief and 75% interest relief.
How many years back do I go in a voluntary disclosure?
For foreign income or assets, the CRA asks for the most recent 10 years that contain errors or omissions.
Sources
- CRA: Table of penalties, foreign reporting (modified 20 Oct 2026) · accessed Oct 2026
- CRA: Questions and answers about Form T1135 (modified 19 Oct 2026) · accessed Oct 2026
- CRA: Changes to the Voluntary Disclosures Program (effective 1 Oct 2025) · accessed Oct 2026
- CRA: Voluntary Disclosures Program (modified 15 Jun 2026) · accessed Oct 2026
This article is general information, not financial, legal or tax advice. Products described are provided under the terms on this site and are subject to regulation and eligibility.