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An FBAR is a US report of foreign bank and financial accounts, and you file it if you’re a US person whose foreign accounts added together were worth more than US$10,000 at any point in the year. Living in Canada doesn’t change that. But Canada has its own, separate foreign-property form, the T1135, with a different test.
Who has to file an FBAR
The IRS says a “U.S. person” means a citizen, a resident, or an entity such as a corporation, partnership, LLC, trust or estate. The report is filed with FinCEN, part of the US Treasury, as FinCEN Form 114. It isn’t part of your US tax return, and the IRS states plainly that you don’t file it with your federal return.
For most people in Canada the real question is if they count as a US person at all. We can’t decide that for you, and this page isn’t the place to guess. Check the IRS definition, then ask a cross-border tax accountant if you’re still unsure. That’s one of the few cases where an accountant earns the fee.
What counts toward the $10,000
Any financial account held outside the US can count. The IRS names bank accounts, brokerage accounts and mutual funds. It doesn’t matter if the account earns taxable income. The $10,000 is a total across all your foreign accounts, so two accounts of US$6,000 each trigger the filing even though neither is over the line alone.
The IRS lists exceptions, including IRAs and some retirement plans. We couldn’t confirm on an official page how Canadian accounts such as an RRSP or a TFSA are treated, so check that before you count them in or out.
FBAR and T1135 side by side
| FBAR | T1135 | |
|---|---|---|
| Country | United States (FinCEN) | Canada (CRA) |
| Who | US persons | Canadian residents (individuals, corporations, some trusts) |
| Test | Foreign accounts above US$10,000 in total, at any time in the year | Specified foreign property that cost more than $100,000 in total, at any time in the year |
| Detail level | One report | Simple form up to $250,000, detailed from $250,000 |
| Due date | April 15 after the year, automatic extension to October 15 | April 30 for most individuals, June 15 if self-employed |
| Filed with the tax return | No, filed online with FinCEN | Separate form, see the CRA page |
The T1135 test uses what the property cost you, not its value today. Personal-use property, business property and some other items are excluded. The CRA’s page lists them.
Form T1135 is due on the same date as the income tax return.
Foreign Income Verification Statement, Canada Revenue Agency, canada.ca
What should you have on hand before you file?
Gather the basics for every foreign account: the name and address of the bank or broker, the account number, the type of account and the highest balance it reached during the year. The FBAR looks at that peak, so a balance that sat at US$3,000 most of the year and spiked to US$11,000 for a week still counts. Convert amounts to US dollars using the rate the form instructions tell you to use.
For the T1135 the CRA wants cost, not value, plus income and any gain or loss, so keep the purchase records. Marta in Kitchener, who bought US shares in 2019 for $130,000, can’t just look at the quote on her app. She needs the original cost in Canadian dollars.
An example with two thresholds
Say you’re a Canadian resident and a US citizen. You hold a US brokerage account that cost you $120,000, plus a US bank account with US$4,000. The T1135 applies, since foreign property cost more than $100,000, and the simple version is enough because it’s under $250,000. The FBAR applies as well, because the two accounts together are over US$10,000.
That’s two forms, two agencies and two dates for one set of accounts. If only one test is met, you file only that one.
Dates and what to do this fall
Plenty of dual citizens only think about the US side at Canadian tax time, and by then the FBAR date has often passed. Put both dates in your calendar together, and set a reminder for the US one in early April.
For 2025 accounts, the FBAR was due April 15, 2026, and the IRS’s automatic extension runs to October 15, 2026. That is only a few days away if you’re reading this in mid-October. FinCEN also posts disaster-relief extensions, so check its page for your case. The 2026 dates aren’t out yet.
Missed a year? The CRA says penalties can be significant for late or false T1135 filings, and the page we used gave no amounts. We didn’t confirm the FBAR penalties. Read the source pages before you act.
Tax you still pay in Canada
Reporting accounts is one thing. Does it also change what you owe? Tax is another matter. Interest, dividends and gains from foreign accounts belong on your Canadian return if you’re a resident. To see the effect, try the income tax calculator, the capital gains tax calculator and the dividend tax calculator. More tools are in the income tax hub.
Where the numbers come from
The FBAR rules come from the IRS page on the report of foreign bank and financial accounts and from FinCEN, for 2025 reporting. The T1135 rules come from the CRA‘s page on the foreign income verification statement. We checked the thresholds against those pages and did not verify anything else. We’re not connected with the IRS, FinCEN or the CRA.
Frequently asked questions
What is an FBAR?
It's a US report of foreign bank and financial accounts, filed with FinCEN as Form 114 by US persons whose foreign accounts total more than US$10,000 at any time in the year.
Is the FBAR the same as the T1135?
No. The FBAR is a US report with a US$10,000 account test. The T1135 is a CRA form for Canadian residents with specified foreign property that cost more than $100,000.
Do I file an FBAR with my tax return?
No. The IRS says you don't file it with your federal return. It goes online to FinCEN.
When is the FBAR due for 2025?
April 15, 2026, with an automatic extension to October 15, 2026. Check FinCEN for any disaster relief extension. We haven't seen 2026 dates.
Does a Canadian bank account count?
Any financial account outside the US can count for a US person. We couldn't confirm the treatment of RRSPs and TFSAs on an official page, so check it.
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