FBAR FinCEN Form 114: Canadians who become US persons must file at USD 10,000

Section 01Section 1. Why this topic exists in your life as a Canadian in Florida

A Canadian snowbird who keeps Canadian residency and properly files Form 8840 each year does not file FBAR. The form is a US-person obligation, identical in scope to who-must-file Form 8938 (see our dedicated guide on FATCA Form 8938). The trigger is becoming a US person.

The reason FBAR matters specifically for Canadians is the threshold: USD 10,000. That is so low that essentially any Canadian who becomes a US person and has not closed their Canadian banking relationships will cross it. A single chequing account with a paycheque deposit, a small RRSP from a previous job, or even a joint family account at Desjardins where you have signature authority alone can put you over.

Three triggers activate FBAR for a Canadian:

The green card. The day USCIS issues you a permanent resident card, you are a US person. The first FBAR is due the April 15 following the calendar year of issuance.

The Substantial Presence Test. A Canadian who fails Form 8840 protection and meets SPT becomes a US tax resident for the year. FBAR follows.

US citizenship. A dual citizen by birth, by descent, or by naturalization is always a US person and always subject to FBAR if accounts exceed threshold, regardless of where they live.

Snowbirds who maintain Canadian residency and file Form 8840 on time have no FBAR exposure. Permanent movers, green card holders, and accidental Americans (US citizens by birth who have lived in Canada all their lives) all do.

Section 02Section 2. Who must file: the US person definition for FBAR purposes

The FinCEN regulations at 31 CFR § 1010.350 define a "United States person" for FBAR purposes as: a citizen of the United States, a resident of the United States, an entity (including a corporation, partnership, LLC, or trust) created or organized under US law. The "resident" subcategory uses the same Substantial Presence Test as the IRS uses for income-tax purposes.

A Canadian dual citizen by birth: US person, FBAR required if threshold is crossed.

A Canadian green card holder: US person from issuance, FBAR required.

A Canadian who meets SPT for a calendar year (with no Form 8840 protection and no treaty tie-breaker successfully invoked): US person for that year, FBAR required.

A Canadian snowbird who properly files Form 8840 by June 15 of the following year, breaks SPT through Closer Connection: NOT a US person, FBAR not required for that year.

A Canadian who loses the treaty tie-breaker analysis (Article IV) and is classified as a US tax resident for treaty purposes: US person, FBAR required.

A US citizen who lives full-time in Canada (the "accidental American"): US person, FBAR required for life unless citizenship is renounced under IRC § 877A.

A non-US-person Canadian spouse of a US-person Canadian: NOT a US person individually; their separate accounts are not reported. But a joint account where the US-person spouse has signature authority IS reported (at full value, not half).

Signature authority deserves special attention. A Canadian who becomes a US person and has signature authority over a parent's account in Canada (often a power-of-attorney arrangement for an aging parent), or signature authority over a Canadian small-business account, must report those accounts on FBAR even though they have no beneficial ownership. The regulation makes no economic-interest distinction at this layer.

Section 03Section 3. Reportable accounts, item by item

The reportable category overlaps substantially with Form 8938 but is broader on signature authority and narrower on certain non-account assets.

Reportable on FBAR:

Canadian chequing and savings accounts at any Canadian bank, credit union, or caisse populaire (Desjardins, RBC, TD, BMO, Scotia, CIBC, National Bank, Tangerine, EQ Bank, Simplii, etc.).

Canadian GICs and term deposits.

Canadian brokerage accounts at full-service or discount brokers (RBC Direct Investing, TD Direct Investing, BMO InvestorLine, Disnat, Wealthsimple Trade, Questrade, Interactive Brokers Canada, NBDB).

Canadian registered accounts treated as financial accounts: RRSP, TFSA, RESP, FHSA, RRIF, LIRA, LIF, RDSP. Pension plans and IPPs may also be reportable depending on the account structure (pooled vs individual).

Canadian mutual fund accounts.

Canadian-issued life insurance and annuity contracts with cash surrender value.

Foreign branches of US banks (e.g., Citibank Mexico account held by a US-person Canadian). The branch location, not the bank's home, determines foreign status.

Account held in nominee name where the US person is the actual beneficial owner.

Joint account with a non-US person spouse, child, or business partner, where the US person has signature authority. The full account value is reported.

NOT reportable on FBAR:

Accounts at US branches of any bank, even if the parent is foreign. RBC Bank US, BMO Harris, TD Bank US are US accounts. They appear on the 1040; they do not appear on FBAR.

Real estate held directly. A Florida condo or a Canadian cottage held in personal name is not a financial account.

Personal-use assets (cars, art, jewelry).

Cryptocurrency held in self-custody (no third-party financial institution). The FinCEN rule on virtual currency held at foreign exchanges is in evolving status; FinCEN proposed in 2020 to bring foreign crypto exchanges within FBAR but the regulation has not been finalized as of 2026. Current FinCEN guidance is that crypto-only foreign exchange accounts are NOT reportable, but Canadians should monitor this category.

Accounts owned by a non-US-person spouse where the US-person Canadian has neither beneficial interest nor signature authority.

Canada Pension Plan / Quebec Pension Plan entitlements not yet claimed (these are government pensions, not financial accounts).

The form requests, for each account: type of account, financial institution name and address, account number, and the maximum value during the calendar year converted to USD at the year-end Treasury exchange rate. Approximate values are acceptable when exact figures cannot be obtained.

Section 04Section 4. The thresholds, calculation, and aggregation

The threshold is USD 10,000 in aggregate maximum balances during the calendar year. "Aggregate" matters: if a Canadian has three Canadian accounts, none of which individually exceeds USD 10,000, but whose combined max-during-the-year balances total USD 12,000, FBAR is required.

The calculation is mechanical:

For each foreign account: the maximum value during the calendar year, in the account's denomination currency, is converted to USD using the Treasury Bureau of the Fiscal Service year-end exchange rate (published annually).

If the aggregate of those USD-equivalent maximums exceeds USD 10,000, FBAR is required and ALL foreign accounts must be reported, including those with zero or negligible balances.

A Canadian who becomes a US person on July 1, has CAD 8,000 in a chequing account on December 31, but had a CAD 25,000 GIC that matured into the chequing account on June 15 (before becoming a US person), still reports on FBAR because the threshold test applies to the calendar year as a whole, not the US-person portion of the year. (Different IRS interpretations exist on this point for dual-status arrivals; cross-border CPAs typically take the conservative view and file.)

A Canadian green-card holder who lives in Canada full-time has the same USD 10,000 threshold (no abroad-tier increase as exists for Form 8938).

Joint accounts: full value reported by EACH joint owner who is a US person. Two US-person spouses with one CAD 30,000 joint account each report USD 22,000-equivalent on their respective FBARs (or one joint FBAR if filed jointly under specific rules).

Signature authority but no beneficial interest: full value reported, but the form has a specific section for this category and the account is reported on Part IV rather than Part II.

Section 05Section 5. FBAR vs Form 8938 vs T1135: the side-by-side

The single most consequential difference for Canadians is the FBAR threshold (USD 10,000) versus the Form 8938 threshold (USD 50,000+). A Canadian US person with USD 30,000 in Canadian chequing and savings files FBAR but not 8938. A Canadian US person with USD 60,000 files both. A Canadian US person with multiple low-balance accounts that aggregate above USD 10,000 files FBAR even if no single account is large.

Section 06Section 6. Worked example: an Ottawa engineer green-cards to Tampa

A 42-year-old electrical engineer from Ottawa accepts an EB-2 priority-worker green card sponsored by a Tampa employer. The card is issued on April 12, 2026. He physically relocates June 1, 2026. His Canadian banking on April 12:

• Tangerine chequing: CAD 4,800 (max during year: CAD 6,200 in February)
• TD Direct Investing taxable account: CAD 18,400 (max: CAD 24,000 in March, before he liquidated some positions)
• TD RRSP: CAD 86,000 (max: CAD 91,000 in March)
• TFSA at Wealthsimple: CAD 41,000 (max during year)
• LIRA from a previous federal-government employer: CAD 22,000
• Joint chequing with his spouse at TD Canada Trust (he is a US person from April 12; she remains Canadian): CAD 17,000 (max: CAD 19,500)

USD/CAD year-end Treasury rate (assume 1.36 for 2026): aggregate max value approximately USD 153,000.

Test: He is a US person for the entire calendar year 2026 (green card from April 12; the IRS generally applies the green card test for the full calendar year of issuance unless the dual-status election is more advantageous).

Threshold test: USD 153,000 well exceeds USD 10,000. FBAR is required.

He files FinCEN Form 114 by April 15, 2027 (or by October 15, 2027 under the automatic extension), reporting all six accounts including the joint chequing at full value (USD 14,300 equivalent).

He also files Form 8938 (his aggregate exceeds the USD 50,000 single-resident threshold).

He also files Form 3520 and Form 3520-A for the TFSA (foreign grantor trust treatment).

If he had failed to file FBAR for one year and the IRS later detected it through FATCA reporting from his Canadian banks, the non-willful penalty could be USD 10,000 per violation. Recent IRS guidance (post Bittner v. United States, 2023 Supreme Court decision) treats the non-willful penalty as per FORM, not per ACCOUNT, capping the per-year exposure at USD 10,000 rather than USD 60,000 (one per account). But the willful tier remains per-account.

Section 07Section 7. The IRS Streamlined Filing Compliance Procedures: catch-up pathway

Most Canadians who become US persons learn about FBAR years after they should have started filing. The most common scenario: a Canadian who got a green card years earlier, never thought about FBAR, and is now selling a Canadian asset that generates a Schedule B disclosure on the 1040 that triggers a question about foreign accounts.

The IRS Streamlined Filing Compliance Procedures, introduced in 2014 and updated several times since, allow non-willful filers to catch up with reduced exposure:

Streamlined Foreign Offshore Procedures (SFOP): for US persons who reside abroad. Requires:

• Three years of amended or original 1040 filings
• Six years of FBAR filings
• A signed certification of non-willfulness
• Zero miscellaneous offshore penalty (only any underpaid income tax plus interest)

Streamlined Domestic Offshore Procedures (SDOP): for US persons who reside in the United States. Requires:

• Three years of amended or original 1040 filings
• Six years of FBAR filings
• A signed certification of non-willfulness
• Miscellaneous offshore penalty of 5 percent of the highest aggregate year-end account balance over the six-year period

Both procedures are open only to taxpayers whose past failure was non-willful. A Canadian who actively concealed accounts, used nominees, or made false statements on prior returns cannot use Streamlined; they must use the IRS Voluntary Disclosure Practice (VDP) which carries higher penalties but provides protection from criminal prosecution.

Streamlined is closed once the IRS has commenced an examination or made contact about a foreign account. A Canadian who receives an IRS notice asking about a Canadian account should consult a cross-border tax attorney IMMEDIATELY, because Streamlined is no longer available and continued silence escalates the situation.

Section 08Section 8. Common mistakes Canadians make on FBAR

Believing the threshold is per account rather than aggregate. The threshold is the AGGREGATE of all foreign accounts.

Believing that filing Form 8938 satisfies FBAR. The two are entirely separate filings with separate agencies.

Failing to file because "the account had no income." FBAR is information-only; it does not depend on income. A zero-income chequing account is reportable if the threshold is crossed.

Excluding RRSPs because of treaty tax deferral. Treaty Article XVIII defers the income tax, not the reporting obligation.

Excluding signature-authority accounts. A Canadian with signature authority on an aging parent's Canadian account, or on a Canadian small-business account, must report.

Filing FBAR with the 1040. FBAR is filed separately, electronically, through the FinCEN BSA E-Filing System.

Filing FBAR late through normal channels rather than via Streamlined. Late FBAR filing without Streamlined exposes the filer to the full per-violation penalty schedule.

Joint US-citizen-and-non-citizen-spouse couples filing one FBAR. The non-US-citizen spouse is not a US person and does not file. The US-person spouse files alone, reporting joint accounts at full value.

Leaving columns blank when exact balance unknown. The form accepts approximate values; leaving blank is treated as a defective filing.

Section 09Section 9. Action checklist for a Canadian becoming a US person

1. Identify the trigger date (green card issuance, first day of US tax residency under SPT, or US-citizenship recognition).
2. List every Canadian financial account where you have a financial interest or signature authority, including small-balance accounts, joint accounts, and spouse-of-record accounts.
3. Obtain the maximum balance during the calendar year for each account.
4. Convert to USD at the Treasury year-end rate.
5. Sum the converted maximums. If the total exceeds USD 10,000, FBAR is required.
6. Create a FinCEN BSA E-Filing System login at https://bsaefiling.fincen.treas.gov/.
7. Complete FinCEN Form 114, listing each foreign account in Part II (financial interest) or Part IV (signature authority only).
8. Submit electronically by April 15 (automatic extension to October 15).
9. Retain a copy of the filed form and the BSA confirmation receipt for at least six years.
10. Set an annual recurring reminder to re-file FBAR every year you remain a US person.
11. If you have not filed FBAR for past years where you should have, consult a cross-border tax attorney about Streamlined Filing Compliance Procedures BEFORE filing anything else.
12. If you are entering Streamlined, gather all bank statements, brokerage statements, and registered-account statements for the past six years; gather supporting documentation for non-willfulness (your honest belief that filing was not required).

Section 10Section 10. What this guide does not cover

The Canadian-side reporting of US accounts (Form 1099 reporting by US payers) for Canadians who hold US bank or brokerage accounts.

The CBSA Form E667 currency reporting at the border for cash above CAD 10,000 (this is a distinct cross-border movement of currency, not an account holding).

The Form 8854 expatriation reporting for green card holders who surrender after 8 of 15 years and US citizens who renounce.

PFIC reporting on Form 8621 for Canadian mutual fund and ETF holdings; this is an income-tax obligation distinct from FBAR.

Specific Canadian provincial banking products (Quebec caisses populaires reporting protocols, Ontario credit union deposit insurance limits) which may affect the reporting institution name format.

Section 11Section 11. FAQ

Is FBAR the same as Form 8938? No. FBAR is FinCEN Form 114 filed with Treasury; Form 8938 is filed with the IRS as part of the 1040. Most Canadians who become US persons file both. The thresholds and penalty schedules differ.

Do I file FBAR if I am a Canadian snowbird with Form 8840 protection? No. FBAR is a US-person obligation. A Canadian who validly breaks SPT through Closer Connection is not a US person.

My RRSP is tax-deferred under the treaty. Do I still report it on FBAR? Yes. The treaty defers income tax, not reporting. The RRSP is a Canadian financial account and is reportable.

My spouse is Canadian (not a US person). Do we file one FBAR or two? Two, if both have foreign accounts. The non-US-person spouse does not file at all. The US-person spouse files alone, including joint accounts at full value.

How do I file FBAR? Electronically through the FinCEN BSA E-Filing System at https://bsaefiling.fincen.treas.gov/. Paper filing is not accepted.

When is FBAR due? April 15 of the following year, with an automatic extension to October 15. No request for extension is required.

What if I miss the deadline? Filing late through normal channels exposes you to the per-violation penalty. If your past failure was non-willful, the Streamlined Filing Compliance Procedures may allow catch-up with reduced or zero penalty. Consult a cross-border tax attorney before filing anything late.

How do I document signature authority? The form asks for the title of your role (e.g., "Power of Attorney for [name]," "Director of [Canadian corporation]"). The form does not require uploading the underlying document, but you should retain it for the six-year statute of limitations.

Is cryptocurrency held at a Canadian exchange reportable? Current FinCEN guidance is that virtual-currency-only foreign accounts are not reportable. A 2020 FinCEN proposal would have included them, but the regulation has not been finalized as of 2026. Monitor for change.

Does FBAR generate a US tax bill? No. FBAR is information-only. The income generated by the reported accounts goes on the 1040 (interest, dividends, capital gains) and is taxed there, with foreign tax credit relief for Canadian tax already paid.

Can the IRS see my Canadian accounts even if I don't file FBAR? Yes. Under the FATCA intergovernmental agreement, Canadian financial institutions report US-person account holders to the CRA, which transmits the data to the IRS. The IRS already knows about your largest accounts. Voluntary disclosure (Streamlined) is materially safer than waiting for IRS contact.