The Northern Office — Canada, est. 2024

The FBAR file

Do I need to file an FBAR?

If you are a US person, the US wants a yearly list of every account you hold outside America once they add up to more than $10,000. Add your accounts and see where you land.

Quick answer: if you are a US person and your accounts outside the US together top $10,000 USD at any point in the year, you must file the FBAR (FinCEN Form 114). It counts your TFSA, RRSP, and chequing accounts, and it is separate from your tax return.

Your non-US accounts

For each account, enter its highest balance during the year in US dollars. The test looks at the peak, not the year-end number.

$
$
$

Your result

$13,000

Over the line

combined peak against the $10,000 threshold

You are over the $10,000 line, so you almost certainly need to file the FBAR (FinCEN Form 114). It is filed online through the BSA E-Filing system, separate from your tax return, listing every non-US account by name, number, and peak balance.

The basics

  • Form: FinCEN Form 114, the FBAR.
  • Where: the BSA E-Filing system, not with your 1040.
  • Due: April 15, with an automatic extension to October 15.
  • What counts: chequing, savings, TFSA, RRSP, RESP, investment accounts, most things held outside the US.

What it costs to skip it

The penalties are steep. For an honest mistake (non-willful), up to about $16,000 a year. The Supreme Court's 2023 Bittner decision confirmed that this non-willful penalty is charged per yearly report, not per account. If the IRS decides you hid accounts on purpose (willful), it climbs to the greater of about $165,000 or half the account balance. These figures adjust for inflation each year.

FBAR is not Form 8938

People mix these up. The FBAR goes to FinCEN. Form 8938 (FATCA) is a separate form filed with your tax return, with higher thresholds. Many US persons in Canada end up filing both.

Let the count run itself.

Being Canadian tracks your days and balances in the background and warns you before you cross a line, on both the US clock and your provincial one. Get on the list and you walk in first this Canada Day.

General information, not tax or legal advice. Confirm your own filing with a cross-border professional. Rules verified 2026-05-21. Source: FinCEN BSA E-Filing.

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