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I'm a US citizen living in Canada — how many tax returns do I actually file each year?

⚠️ Disclaimer: For general information only — not tax, financial, or legal advice. Figures may be outdated or incorrect; tax rules change frequently. Verify important decisions with the CRA/IRS or a qualified professional. You use this information at your own risk.
The short answer

Five, at minimum. The US taxes citizens on worldwide income no matter where they live, and Canada taxes residents on worldwide income — so you file a full set on both sides, plus information returns. Miss one and the penalties start without anyone sending you a reminder.

The annual stack

#FormWhereWhat it covers
1Form 1040US (IRS)Worldwide income
2FinCEN Form 114 (FBAR)US (FinCEN, filed separately)Foreign accounts, aggregate >$10,000
3Form 8938US (attached to 1040)Specified foreign assets over threshold
4T1Canada (CRA)Worldwide income
5T1135Canada (with T1)Foreign property, cost >CAD $100,000

Form 8938 thresholds for taxpayers living abroad: single $200,000 on the last day of the year (or $300,000 at any point); married filing jointly $400,000/$600,000. The T1135 threshold is CAD $100,000 measured on cost amount, not market value — a detail that trips people up.

Deadlines that matter

FilingDeadlineExtension
1040 (abroad)April 15Automatic to June 15 (no form; but tax owed still due April 15); to Oct 15 with Form 4868
FBARApril 15Automatic to October 15 — no request needed
T1 (Canada)April 30June 15 if self-employed (balance due April 30)
T1135Same as T1Same as T1

Note the FBAR trap: it is filed with FinCEN's BSA E-Filing system, not with your tax return — extending your 1040 does not extend your FBAR (though the FBAR has its own automatic extension).

Frequently asked questions

Do I really need Form 8938 if I already file FBAR?

Often yes — they overlap but neither replaces the other. FBAR goes to FinCEN with lower thresholds; 8938 goes to the IRS with higher thresholds and covers a broader asset range. When in doubt, file both.

What if I've missed FBARs for prior years?

Don't just start filing going forward and hope. The IRS has streamlined filing procedures for non-willful filers that can massively reduce penalties — but you generally need to act before the IRS contacts you. Talk to a cross-border CPA first.

Can the foreign tax credit wipe out my US tax?

Frequently yes, since Canadian rates are generally higher — but the credit has per-category limits (see our FTC guide), and it never reduces the filing obligation.

Sources

  • https://blueskyic.com/insights/us-pension-transfer
  • IRS: Form 8938 thresholds — https://www.irs.gov/businesses/corporations/do-i-need-to-file-form-8938-statement-of-specified-foreign-financial-assets
  • FinCEN FBAR help (automatic Oct 15 extension) — https://bsaefiling.fincen.gov/docs/FinCENFBARHelp.pdf
  • CRA: T1135 foreign income verification — https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/information-been-moved/foreign-reporting/foreign-income-verification-statement.html
Disclaimer — please read. This article is for general information and educational purposes only. It is not tax, accounting, legal, financial, or immigration advice, and reading it does not create a professional or client relationship between you and Llandora. Tax and immigration rules change frequently and differ by country, province/state, and personal circumstances; figures, thresholds, and examples in this article may be outdated, incomplete, or incorrect, and may not apply to your situation. Always verify current rules with the official sources (CRA, IRS, IRCC, USCIS) and consult a licensed professional before making any decision. Llandora makes no warranty of any kind — express or implied — about the accuracy, completeness, reliability, or timeliness of this content. To the fullest extent permitted by law, Llandora disclaims all liability for any loss, damage, cost, or expense arising from errors or omissions in this article or from any action taken or not taken in reliance on it, whether direct, indirect, incidental, or consequential. You rely on this article entirely at your own risk.