Many Americans in Canada must file both. The FBAR goes to FinCEN online, the Form 8938 goes with your tax return, and the thresholds are different.
Lou is a tax-preparation tool, not a tax advisor. This article explains general rules for US citizens and green card holders who live in Canada. For advice on your situation, work with a qualified tax professional.
If you have Canadian bank, investment or registered accounts, two US reports can apply to you. They look alike, which is why people mix them up.
The short comparison#
| Item | FBAR (FinCEN Form 114) | Form 8938 |
|---|---|---|
| Filed with | FinCEN, online only | Your Form 1040 |
| Main trigger | More than $10,000 total in foreign accounts at any time in the year | $200,000 at year end or $300,000 at any time (single, living abroad) |
| Married filing jointly, living abroad | Same $10,000 test | $400,000 at year end or $600,000 at any time |
| Due | April 15, automatic extension to October 15 | With your return |
| What counts | Financial accounts | Accounts plus other foreign financial assets |
The FBAR#
The FBAR is not part of your tax return and there is no tax on it. It is filed only through the FinCEN BSA E-Filing System, with no paper version and no fee. Each account is reported at its highest balance during the year, converted to US dollars at the US Treasury rate for December 31 and rounded up to the next dollar.
Only US persons file an FBAR. A Canadian spouse who is not a US person does not file one. If you share an account with someone, each US person who owns it reports the full value.
Form 8938#
Form 8938 is a FATCA form that goes with your return. It covers the same accounts plus other foreign assets, such as an employer pension. The thresholds are much higher for people who live abroad than for people who live in the US.
Registered accounts#
RRSP, RRIF, TFSA, RESP and FHSA accounts held at a Canadian institution are reportable on the FBAR and count toward Form 8938. An RRSP being tax-deferred does not remove it from either report.
Both can apply to you#
The tests are separate. You can owe an FBAR without crossing the Form 8938 threshold, and a Form 8938 filing does not replace the FBAR. File each one when its own test is met. See the FBAR guide and the Form 8938 guide.
Exchange rates#
Both reports use year-end values, so use the right rate. The exchange rate guide lists the Treasury rates by year.
Where Lou fits#
You enter each account once. Lou gives you an FBAR worksheet to copy into the FinCEN site and prepares Form 8938. Lou does not file the FBAR for you.
Free to try. You pay only when you are ready to download your forms.