I'm a Canadian tax resident with a US bank account — do I need to file FBAR?
Only if you are also a "US person" — and for FBAR purposes that includes more people than you'd think. The FBAR rule keys off US personhood, not where you live: US citizens, green-card holders, and anyone who meets the substantial presence test (i.e., US tax residents) must report. If you are purely a Canadian citizen living in Canada with no US status, a US bank account alone does not trigger FBAR.
Who counts as a US person for FBAR
| Status | US person? |
|---|---|
| US citizen (wherever living) | Yes |
| Green-card holder | Yes |
| Meets the substantial presence test | Yes — this is the one people miss |
| Canadian citizen, Canadian resident, no US status | No |
The substantial presence test counts your days in the US over a 3-year weighted formula (all days this year + 1/3 of last year + 1/6 of two years ago ≥ 183). Snowbirds who winter in Arizona or Florida can trip into US tax residency without realizing it — and with it, the FBAR obligation.
The $10,000 trigger
If you are a US person, you must file FinCEN Form 114 when the aggregate maximum value of all your foreign financial accounts exceeds $10,000 at any time during the calendar year. Key nuances:
- Aggregate — add up every foreign account's highest balance, not each account separately.
- Any time — a single large transfer passing through for a day can trigger the filing.
- Exceeds — exactly $10,000 does not trigger it; $10,000.01 does.
- Per-account maxima are converted to USD at the Treasury's December 31 rate, then summed.
Deadline: April 15, with an automatic extension to October 15 — no request needed.
Frequently asked questions
I'm a dual US-Canadian citizen living in Toronto. My US account has $8,000 and my Canadian accounts total $50,000. Do I file?
The US account is not "foreign" to the US — but your Canadian accounts are foreign financial accounts to a US person. Their aggregate maximum ($50,000+) exceeds $10,000, so yes, you file, reporting the Canadian accounts.
Does FBAR mean I owe tax on the accounts?
No. FBAR is an information report, not a tax. But the income those accounts earn is taxable on your 1040 — and failing to file the FBAR carries its own penalties, separate from any tax.
I closed the account mid-year. Still reportable?
If the aggregate maximum exceeded $10,000 at any point while you held it, yes — report the account with its maximum value and note it was closed.
Sources
- https://bbs.fcgvisa.com/t/401k-ira/53529
- FinCEN: purpose of the FBAR — https://www.fincen.gov/purpose-fbar
- FinCEN FBAR filing help — https://bsaefiling.fincen.gov/docs/FinCENFBARHelp.pdf
- IRS: substantial presence test — https://www.irs.gov