File FinCEN Form 114 (the FBAR) if the combined highest balances of all your foreign accounts were more than $10,000 US at any time during the year. For most Americans in Canada, that's every year.
It reports accounts, not income, and there is no tax on it. It is filed online through FinCEN's BSA E-Filing System, not with your Form 1040. Due April 15, with an automatic extension to October 15.
Do you need to file?
You file if you are a US person (citizen or green card holder) with a financial interest in, or signing authority over, foreign financial accounts whose maximum values added together were more than $10,000 at any time in the calendar year. A $6,000 chequing account and a $5,000 TFSA means you file, even though neither account passed $10,000 alone.
Count all of these:
- Chequing and savings accounts, GICs
- Investment and brokerage accounts
- RRSP, RRIF, TFSA, FHSA and RESP accounts
- Accounts you can sign on but don't own, such as a parent's account or your employer's
CPP and OAS are government benefits, not accounts, so they don't go on the FBAR.
Joint accounts and spouses
Each US person who owns a joint account reports the full value of the account, not half. A spouse who is not a US person doesn't file an FBAR at all. Spouses who are both US persons can file one joint FBAR in some cases, using Form 114a.
Values and exchange rates
For each account you report its highest balance during the year, converted to US dollars with the US Treasury's reporting rate for December 31 of that year, then rounded up to the next whole dollar. This is a different rate from the IRS yearly average used on your tax return.
Divide the Canadian dollar balance by the rate. Example: a highest balance of CA$20,000 in 2025 is $20,000 ÷ 1.369 = $14,609.20, reported as $14,610.
Deadline and how to file
The FBAR is due April 15 for the previous calendar year, with an automatic extension to October 15. You don't need to ask for it. It is filed only through FinCEN's BSA E-Filing System; there is no paper version and no fee. Keep your account records for five years.
If you missed years
For non-willful violations, the maximum civil penalty is $16,536 per late report (the 2025 inflation adjustment). In Bittner v. United States (2023) the Supreme Court held that this penalty applies per report, not per account. Willful violations carry much larger penalties.
If you didn't know you had to file, the Streamlined Foreign Offshore Procedures let you file the last six years of FBARs with no penalty, as part of catching up your returns. See Catching up on missed years.