FBAR for Americans Living in Canada: Who Must File?

Americans living in Canada may have to report Canadian financial accounts to the US Treasury even when those accounts are completely ordinary in Canada.

The main foreign-account reporting requirement is the Report of Foreign Bank and Financial Accounts, commonly called the FBAR.

FBAR is filed on FinCEN Form 114. It is separate from a US income tax return and is not the same thing as FATCA Form 8938.

The most important threshold is straightforward: a US person generally has an FBAR filing requirement if the aggregate value of reportable foreign financial accounts exceeds US $10,000 at any time during the calendar year.

The threshold applies to the combined value of relevant foreign accounts, not $10,000 per account.

Who Must File an FBAR?

A US person may need to file an FBAR if both of the following apply:

• the person has a financial interest in, or signature or other authority over, at least one financial account located outside the United States; and
• the aggregate value of all reportable foreign financial accounts exceeds US $10,000 at any time during the calendar year.

For FBAR purposes, a US person can include US citizens, US residents, and certain US entities.

For Americans living in Canada, Canadian bank and investment accounts are generally foreign accounts because they are maintained outside the United States.

How Does the $10,000 FBAR Threshold Work?

The threshold is based on the combined maximum value of reportable foreign accounts.

For example, imagine a US citizen living in Canada has:

• a Canadian checking account with a maximum value of US $4,000
• a Canadian savings account with a maximum value of US $3,500
• a Canadian brokerage account with a maximum value of US $5,000

The accounts do not need to exceed $10,000 individually.

Their combined value is above $10,000, so an FBAR filing requirement may apply.

The relevant test is whether the aggregate value exceeded $10,000 at any point during the calendar year, not simply the value on December 31.

Which Canadian Accounts May Need to Be Reported?

Reportable foreign financial accounts can include more than ordinary checking and savings accounts.

Depending on the facts, examples may include:

• Canadian checking accounts
• Canadian savings accounts
• Canadian brokerage accounts
• certain securities accounts
• certain mutual fund accounts
• accounts held jointly with another person
• accounts over which the US person has signature or other authority

Whether a particular Canadian account is reportable depends on the legal and factual characteristics of that account.

Do not assume that an account is excluded merely because it is common, tax-preferred, or registered under Canadian law.

Does an Account Have to Generate Income to Be Reported?

No.

For FBAR purposes, whether a foreign financial account produced taxable income does not determine whether the account is reportable.

A Canadian account can therefore create an FBAR reporting obligation even if it earned little or no income.

This distinction is important because FBAR is primarily an information-reporting requirement rather than an income-tax calculation.

What If You Have Joint Canadian Accounts?

Joint ownership does not automatically eliminate an FBAR reporting obligation.

A US person may still have to report a jointly held foreign financial account if the applicable reporting requirements are met.

The treatment of jointly owned accounts can depend on who owns the account, who has authority over it, and the specific filing circumstances.

If you share Canadian financial accounts with a spouse or family member, those accounts should be reviewed rather than assumed to be excluded.

What Does Signature Authority Mean?

FBAR rules can also apply when a US person does not own the money but has signature or other authority over a foreign financial account.

This can arise in certain employment, business, family, or fiduciary situations.

The precise rules and exceptions can be technical, so people with signing authority over corporate or third-party Canadian accounts should review the requirements carefully.

Is FBAR the Same as FATCA Form 8938?

No.

FBAR and Form 8938 are separate reporting requirements.

FBAR is filed with the Financial Crimes Enforcement Network, or FinCEN, using FinCEN Form 114.

Form 8938, Statement of Specified Foreign Financial Assets, is generally filed with the taxpayer's federal income tax return when the applicable Form 8938 requirements and thresholds are met.

Filing Form 8938 does not replace an FBAR filing requirement, and filing an FBAR does not automatically satisfy Form 8938.

FBAR

• filed separately through FinCEN
• focuses on foreign financial accounts
• generally uses the aggregate US $10,000 threshold

Form 8938

• filed with the federal income tax return
• covers specified foreign financial assets
• has different thresholds depending on filing status and whether the taxpayer lives abroad

A taxpayer may be required to file one, both, or neither depending on the circumstances.

Do Americans Living in Canada Get a Higher FBAR Threshold?

No special higher FBAR threshold applies simply because a US person lives in Canada or another foreign country.

The general FBAR aggregate threshold remains US $10,000.

This differs from Form 8938, where certain taxpayers living abroad may have higher reporting thresholds than taxpayers living in the United States.

When Is the FBAR Due?

FBAR is an annual filing requirement.

The filing deadline generally follows the annual federal filing cycle, with an automatic extension available under current FinCEN rules.

Because filing procedures and dates can change, taxpayers should confirm the current deadline directly with FinCEN or the IRS for the relevant filing year.

How Is the FBAR Filed?

FBAR is filed electronically with FinCEN rather than as part of Form 1040.

The filing is made through the BSA E-Filing system using FinCEN Form 114.

This is another reason taxpayers sometimes overlook FBAR: completing and filing a US federal income tax return does not automatically mean the FBAR has been filed.

What If You Did Not File FBARs in Prior Years?

Do not assume that the same solution applies to every missed FBAR.

The appropriate compliance approach depends on factors such as:

• whether US income tax returns were filed
• whether foreign income was properly reported
• how many years are affected
• why the FBARs were missed
• whether the conduct was willful or non-willful
• whether other international information returns were also missed

The IRS has streamlined filing compliance procedures that may be available to certain taxpayers whose failures resulted from non-willful conduct.

For qualifying US taxpayers living outside the United States, the Streamlined Foreign Offshore Procedures can address delinquent or amended US returns and delinquent FBARs when the eligibility requirements are met.

Eligibility should not be assumed automatically.

If several years of FBARs or US returns are missing, consider reviewing the entire filing history before submitting corrective filings independently.

Are There Penalties for Missing an FBAR?

FBAR violations can carry significant civil penalties, and the consequences can differ substantially depending on the circumstances.

Factors such as whether the violation was willful or non-willful can be important.

Because penalty rules are fact-specific and can change, this article does not attempt to calculate potential penalties for an individual case.

If you discover a missed FBAR, the safest next step is usually to determine why it was missed, whether related income and forms were correctly reported, and which compliance procedure may apply before filing corrections.

Common FBAR Mistakes Americans in Canada Make

• thinking the $10,000 threshold applies separately to each account
• checking only year-end balances
• assuming an account does not count because it earned no income
• assuming Canadian accounts are exempt because they are ordinary local accounts
• confusing FBAR with Form 8938
• forgetting jointly held accounts
• forgetting accounts over which they have signature authority
• assuming a US tax preparer automatically filed the FBAR with Form 1040
• filing several late FBARs without first reviewing the broader compliance situation

How Does FBAR Fit Into Your Overall US Filing Obligations?

FBAR is only one part of the US international reporting system.

An American living in Canada may also need to consider:

• Form 1040
• foreign tax credits
• Form 8938
• reporting of Canadian investments
• retirement-account treatment
• foreign corporations or businesses
• other international information returns

For a broader overview, read our guide on whether US citizens living in Canada still have to file US taxes.

If you have US retirement accounts and are planning a move, also see what can happen to a 401(k), IRA and Roth IRA when moving to Canada.

Frequently Asked Questions

What is the FBAR threshold for Americans living in Canada?

A US person generally has an FBAR filing requirement when the aggregate value of reportable foreign financial accounts exceeds US $10,000 at any time during the calendar year.

Is the $10,000 FBAR limit per account?

No. The threshold generally applies to the combined value of reportable foreign financial accounts.

Do Canadian bank accounts count for FBAR?

Canadian bank accounts are generally foreign financial accounts for FBAR purposes because they are maintained outside the United States. Whether an individual account must be reported depends on the applicable rules and circumstances.

Do I need both FBAR and Form 8938?

Possibly. They are separate reporting regimes with different rules and thresholds. Filing one does not automatically satisfy the other.

Do I file FBAR with my US tax return?

No. FBAR is filed separately with FinCEN using FinCEN Form 114.

What should I do if I missed FBARs in previous years?

The appropriate approach depends on the filing history and circumstances, including whether the failure was willful or non-willful. Some taxpayers may qualify for streamlined filing procedures or another compliance option.

Important: This article provides general educational information and is not individualized tax, legal, or financial advice. FBAR and international reporting requirements depend on each person's facts and applicable law.

Official Resources

• IRS — Report of Foreign Bank and Financial Accounts (FBAR)
• FinCEN — Report of Foreign Bank and Financial Accounts
• IRS — Comparison of Form 8938 and FBAR Requirements
• IRS — Streamlined Filing Compliance Procedures
• IRS — Streamlined Foreign Offshore Procedures for US Taxpayers Residing Outside the United States