I'm a US citizen living in Canada — how many tax returns do I actually file each year?
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
| # | Form | Where | What it covers |
|---|---|---|---|
| 1 | Form 1040 | US (IRS) | Worldwide income |
| 2 | FinCEN Form 114 (FBAR) | US (FinCEN, filed separately) | Foreign accounts, aggregate >$10,000 |
| 3 | Form 8938 | US (attached to 1040) | Specified foreign assets over threshold |
| 4 | T1 | Canada (CRA) | Worldwide income |
| 5 | T1135 | Canada (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
| Filing | Deadline | Extension |
|---|---|---|
| 1040 (abroad) | April 15 | Automatic to June 15 (no form; but tax owed still due April 15); to Oct 15 with Form 4868 |
| FBAR | April 15 | Automatic to October 15 — no request needed |
| T1 (Canada) | April 30 | June 15 if self-employed (balance due April 30) |
| T1135 | Same as T1 | Same 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