For US citizens and green card holders living in Canada
FBAR vs T1135: Reporting Foreign Accounts in Both Countries
An American living in Surrey can have foreign assets in both directions: Canadian accounts are foreign to the IRS, and US accounts are foreign to the CRA. Gurleen Kaur, CPA licensed in British Columbia and Washington State, prepares both reports so the numbers agree.
Quick answer
Do US citizens in Canada file both the FBAR and Form T1135?
Many do. The FBAR is a US report, filed with FinCEN, of foreign financial accounts whose combined value exceeded US$10,000 at any time in the year; for an American in Canada, Canadian bank, RRSP and TFSA accounts are the foreign ones. Form T1135 is a Canadian report of specified foreign property costing more than CAD$100,000 at any time in the year; for the same person, US accounts and investments are the foreign ones. IRS Form 8938 can also apply when US thresholds are met.
Side by side
US figures from the IRS FBAR page; Canadian figures from the CRA T1135 page.
| US FBAR (FinCEN Form 114) | Canada Form T1135 | |
|---|---|---|
| What is foreign | Accounts outside the US, such as Canadian bank, investment, RRSP and TFSA accounts | Specified foreign property, such as US bank and brokerage accounts and US investments |
| Threshold | Combined value over US$10,000 at any time in the year | Total cost over CAD$100,000 at any time in the year |
| Measured by | Maximum account value | Cost |
| Simplified option | None | Part A if total cost stays under CAD$250,000 all year |
| Excluded | Certain accounts are exempt; see the IRS FBAR page | Property used exclusively in an active business, shares of a foreign affiliate, personal-use property, certain trust interests |
| Due | April 15, automatically extended to October 15 | April 30 for most individuals; June 15 if self-employed; 6 months after year end for corporations |
| Filed | Electronically with FinCEN, separately from the tax return | With the CRA, alongside the Canadian return |
| Late-filing penalty | Decided under the FBAR penalty rules, including reasonable cause (IRM 4.26.16) | Generally CAD$25 per day for up to 100 days, minimum CAD$100, maximum CAD$2,500, higher if knowing or grossly negligent (CRA) |
And Form 8938
Form 8938 is filed with the US return, separately from the FBAR. For taxpayers living outside the US, it applies when specified foreign financial assets exceed US$200,000 at year end or US$300,000 at any time if unmarried, or US$400,000 and US$600,000 if married filing jointly (IRS comparison). The FBAR and Form 8938 can both be required for the same accounts.
An illustrative example
A hypothetical US citizen in Surrey holds a chequing account, an RRSP and a TFSA in Canada, together worth CAD$80,000, and a US brokerage account that cost US$120,000.
- The Canadian accounts go on the FBAR because they exceed US$10,000 combined.
- The US brokerage account goes on Form T1135 because its cost exceeds CAD$100,000.
- Form 8938 is not required at these values for someone living outside the US.
Hypothetical only; your thresholds depend on exchange rates and your full holdings.
Missed one or both?
Late FBARs can be filed with an explanation, but the IRS removed its separate delinquent FBAR procedure in mid-2026, so penalties follow the normal rules. Late T1135s are handled under the CRA's own rules. Compare the US options in our catch-up guide before filing anything.
Common questions
Do I need to file both the FBAR and T1135?
If you are a US citizen resident in Canada with Canadian accounts over US$10,000 combined and US property costing over CAD$100,000, generally yes. They report different assets to different governments.
Does my RRSP go on the FBAR?
Yes. An RRSP is a foreign financial account for FBAR purposes. The IRS's Rev. Proc. 2014-55 relief removed Form 8891, not the FBAR.
Is the FBAR filed with my tax return?
No. The FBAR is filed electronically with FinCEN, separately from Form 1040. Form 8938, if required, is attached to the tax return.
Why does T1135 use cost instead of value?
The CRA's test is the total cost of specified foreign property, while the FBAR uses each account's maximum value. The same holdings can cross one threshold and not the other.
What is the penalty for a late T1135?
The CRA's penalty is generally CAD$25 per day for up to 100 days, with a minimum of CAD$100 and a maximum of CAD$2,500, and higher penalties apply if the failure was knowing or grossly negligent.
Does Form 8938 replace the FBAR?
No. The IRS comparison chart shows the two have different thresholds and can both be required for the same accounts.
Sources
Every rule and figure on this page links to the IRS, CRA or other official source it comes from. Amounts change; we re-check them before each engagement.
- IRS: Report of Foreign Bank and Financial Accounts (FBAR)
- IRS: IRM 4.26.16, FBAR penalties
- IRS: Comparison of Form 8938 and FBAR requirements
- IRS: Simplified procedures for Canadian retirement plans (Rev. Proc. 2014-55)
- CRA: Foreign income verification statement (Form T1135)
- CRA: Penalties for foreign reporting
Gurleen Kaur, CPA licensed in British Columbia and Washington State. Last updated October 21, 2026. This page is general information, not tax or legal advice for your situation.
Related guides: FBAR and FATCA, TFSA and PFIC, US tax accountant in Surrey, Behind on US filings.
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