Cross-Border Tax · Guide
FBAR for US persons in Canada: the US$10,000 rule
If you are a US citizen or green-card holder living in Canada, you must file an FBAR (FinCEN Form 114) when the combined value of your non-US accounts exceeds US$10,000 at any time in the year — and your Canadian chequing, savings, brokerage, RRSP, and TFSA accounts all count. It is filed electronically, separate from your tax return, and is due April 15 with an automatic extension to October 15.
By the AnalytIQ Accounting team · Last reviewed: August 12, 2026
Who has to file
Any "US person" — citizens (including dual citizens who have never lived in the US), green-card holders, and US tax residents — with financial accounts outside the United States whose combined maximum values exceed US$10,000 at any point in the year. The threshold is aggregate: two accounts that each briefly held US$6,000 put you over.
What counts as an account
- Canadian chequing and savings accounts
- Non-registered brokerage accounts
- RRSPs, RRIFs, TFSAs, and RESPs
- Accounts you only have signing authority over (like a business or elderly parent's account)
How and when to file
The FBAR is filed electronically through FinCEN's BSA e-filing system — it does not go to the IRS with your 1040, and it is not a tax form: no tax is due with it. The deadline is April 15, with an automatic extension to October 15 (no request needed). You report each account's maximum value during the year in US dollars.
Penalties are the reason to take it seriously
Non-willful violations can draw civil penalties per violation (inflation-adjusted, five figures); willful violations run far higher. In practice, the IRS offers clean paths for people who simply didn't know — most commonly the streamlined program, which pairs the missed FBARs with catch-up returns and, for those living outside the US, no penalty.
FBAR vs Form 8938 vs T1135
FBAR goes to FinCEN; Form 8938 (FATCA) attaches to your 1040 with higher thresholds; T1135 is Canada's own foreign-property report for the CRA. A dual citizen in Canada with US investments can plausibly need all three — prepared together so they tell one story.
Source: IRS — Report of Foreign Bank and Financial Accounts (FBAR).
Common questions.
I have never lived in the US. Do I really have to file?
If you are a US citizen — including by birth to a US parent — yes. Citizenship, not residence, creates the obligation. The streamlined program exists precisely for people who discover this late.
Do RRSPs and TFSAs really count?
Yes. Both are non-US financial accounts and belong on the FBAR. (The RRSP also gets favourable treaty treatment on your 1040; the TFSA does not.)
Is there a penalty if I file late myself?
Filing late with a reasonable-cause statement often resolves quietly if you are otherwise compliant. If returns are also behind, the streamlined program is usually the safer route — get advice before filing anything.
Related reading
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