Foreign vacant land - will eventually be developed -T1135?

Tax Topics
1

i have client that has land and structure in Portugal. They will in next couple years develop properties for sale/rental units
i have researched applicability for inclusion on T1135 and not clear if i should include

thanks for any insight

2

If the property is not personal use, you need to file a T1135 if the cost basis is over $100k.

3

that sums it up well.
thankss

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