In a November 24, 2015 Technical Interpretation (2015-0610641C6, Agarwal, Lata), CRA commented on how jointly held property should be reported for Form T1135 purposes.

cost based on amount contributed

CRA noted that each person’s share of the specified foreign property (SFP) would be compared to the $100,000 threshold. Each spouse’s share of the SFP is generally based on the amount contributed by each person toward the cost of the purchase of the property. 

CRA also commented on the situation where one spouse contributes $75,000 towards a SFP purchase, but also gifts $75,000 to his/her spouse, who in turn contributes it towards that SFP purchase as well. It was noted that each spouse’s portion would be $75,000 and, therefore, neither would be required to file the T1135.

Editors’ Comment
CRA’s comments did not mention the attribution rules, which would seem to result in all income and gains on the property in these examples being required to be reported by the spouse who provided the full purchase price. While their comments seem clear that each spouse should report their share of the asset on Form T1135 without consideration of the attribution rules, CRA did not indicate whether income and gains should be reported entirely on the T1135 of the spouse who funded the purchase, consistent with the attribution rules, or should be reported equally on each spouse’s Form T1135, ignoring the attribution rules.