FBAR for Canadians With US Bank or Brokerage Accounts: The $10K Trigger and How to File FinCEN 114

You're a Canadian with a US bank account — maybe a USD savings account at Schwab left over from a work posting in Seattle, maybe a Fidelity brokerage you opened to buy US-listed ETFs, maybe an inherited US account from a relative. You've heard the term “FBAR” and you want to know: do I need to file one?

The answer depends on a single question: are you a “US person” for tax purposes?

If yes — you're a US citizen, a green-card holder, or someone who meets the substantial presence test — the FBAR applies to you. If no — you're a pure Canadian citizen with no US immigration or tax status — you never file an FBAR. Your obligation is to the CRA, not FinCEN, and the form you need is the T1135 (Foreign Income Verification Statement), not FinCEN 114.

That distinction is the single biggest source of confusion in this space. Every top Google result for “FBAR for Canadians” assumes you're a US person living in Canada. Most actual Canadians searching this query are not. Below: both sides of the coin — who files what, the thresholds, the deadlines, the penalties, and a worked example that aggregates three accounts across the border.

Who Is a “US Person” for FBAR Purposes?

The FBAR filing obligation under 31 CFR 1010.350 applies to United States persons. That term covers three categories:

If none of these apply to you, stop here on the FBAR. You are not a US person. You have no FBAR filing obligation regardless of how many US accounts you hold. Skip to the T1135 section below for what you do file.

The US$10,000 Aggregate Threshold — How It Actually Works

The FBAR must be filed if the aggregate maximum value of all your foreign financial accounts exceeds US$10,000 at any point during the calendar year. Three details trip people up:

• Aggregate, not per-account. You add up the peak balances of every foreign financial account you hold. Five accounts worth US$2,500 each = US$12,500 aggregate = FBAR required.
• Maximum value at any point. Not the year-end balance. Not the average. If your Canadian chequing account hit C$15,000 on payday in March but was C$500 by December, you report the C$15,000 peak.
• “Foreign” means outside the US. For a US person living in Canada, Canadian accounts are foreign. Your TD chequing, your RRSP, your TFSA, your Wealthsimple brokerage — all foreign from the FBAR perspective. Conversely, your Schwab or Fidelity account in the US is not foreign for FBAR purposes — it's domestic.

What Counts as a “Financial Account”

Worked Example: Mississauga Dual Citizen With Three Accounts

Priya is a 42-year-old dual citizen (Canadian + US) living in Mississauga. She was born in Michigan, moved to Canada at age 5, and has never filed a US tax return. She holds three accounts:

Step 1 — identify the foreign accounts. The Chase account is a US account — domestic, not reportable on the FBAR. The TFSA and RRSP are Canadian accounts — foreign from the US perspective. Both are reportable.

Step 2 — convert to USD. The FBAR uses the Treasury Department's end-of-year exchange rate (published by the IRS). Assume C$1.00 = US$0.73 for this example:

• TFSA: C$35,000 × 0.73 = US$25,550
• RRSP: C$90,000 × 0.73 = US$65,700

Step 3 — aggregate. US$25,550 + US$65,700 = US$91,250. The aggregate exceeds US$10,000 by a factor of 9.

Result: Priya must file FinCEN 114. She reports both the TFSA and the RRSP. She does not report the Chase account on the FBAR (it's not foreign). She must also check “Yes” on Schedule B, Part III of her Form 1040 and likely file Form 8938 (her specified foreign financial assets exceed US$50,000).

How to File FinCEN 114 (the FBAR) — Step by Step

The FBAR is filed electronically through the BSA E-Filing System operated by FinCEN (the Financial Crimes Enforcement Network). It does not go to the IRS and is not attached to your tax return. Here's the process:

Deadlines

The automatic extension to October 15 was enacted in 2016 (under the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015). Before that, June 30 was the hard deadline with no extensions. The current rule: if you miss April 15, the extension to October 15 applies automatically. No form, no request, no penalty for using it.

FBAR Penalties — The Numbers

FBAR penalties are notoriously severe relative to the filing effort involved. The form takes 15–30 minutes. The penalties for not filing can exceed the account balance.

Applied to Priya's example: She has two reportable accounts (TFSA + RRSP). If she fails to file for three years non-willfully, the maximum penalty exposure is 2 accounts × 3 years × US$10,000 = US$60,000. On accounts worth a combined US$91,250. The penalty can exceed the account value within two years of non-filing.

Pure Canadians: You Don't File an FBAR — You File Form T1135

If you are a Canadian tax resident with no US person status, your US-held bank and brokerage accounts are reportable to the CRA, not FinCEN. The form is T1135 — Foreign Income Verification Statement.

T1135 Threshold and Scope

• Threshold: Total cost of specified foreign property exceeds CAD $100,000 at any point during the year. This is a cost basis threshold, not fair market value (though you report both on the form).
• What counts: Funds in foreign bank accounts (US savings, US brokerage), shares of non-resident corporations held outside a registered account, foreign bonds, and interests in foreign trusts. Does not include personal-use property (US vacation home), property in an active business, or investments held inside an RRSP/TFSA/RRIF (those are already reported to the CRA through the registered account structure).
• Deadline: Same date as your Canadian tax return — April 30 for most individuals, June 15 if you or your spouse are self-employed. The balance-due date is still April 30 regardless.
• Penalties: $25/day late filing (minimum $100, maximum $2,500 per year). Knowing or grossly negligent failures: $1,000/month (maximum $24,000). Plus potential reassessment of unreported foreign income.

Worked Example: Oakville Resident With a US Schwab Account

Marco, age 48, lives in Oakville. He's a Canadian citizen, no US ties. He worked in Chicago from 2015 to 2019 on a TN visa (not a green card), and kept a Schwab brokerage account when he returned. The account holds US$95,000 in US-listed ETFs.

FBAR? No. Marco is not a US person. He had a TN visa (temporary worker), not a green card. He doesn't meet the substantial presence test (he left the US in 2019). He has zero FBAR obligation.

T1135? Depends on cost basis. If the cost basis of his Schwab holdings exceeds CAD $100,000 at any point in 2026, he files the T1135. At US$95,000 × ~1.37 (CAD/USD) = ~C$130,000 fair market value — the cost basis is likely above C$100,000. He files a T1135 with his 2026 return, reporting the account category (funds held outside Canada), the country (US), the cost at the start and end of the year, the income earned, and the gain or loss if any.

Marco also owes Canadian tax on the income earned inside the Schwab account — dividends, interest, and capital gains on any dispositions — reported on his T1 return. He can claim a foreign tax credit for any US withholding on dividends (typically 15% under the treaty).

FBAR vs. T1135: Side-by-Side Comparison

Five Mistakes Cross-Border Canadians Make With the FBAR

1. Thinking the FBAR applies to all Canadians with US accounts. It doesn't. Only US persons. If you're a pure Canadian with a Schwab account, you file a T1135 with the CRA — not an FBAR with FinCEN.
2. Forgetting that the threshold is aggregate, not per-account. Three Canadian accounts at US$4,000 each = US$12,000 aggregate = FBAR triggered. Each account is individually under $10,000; the combined total is what matters.
3. Assuming the RRSP treaty deferral exempts them from FBAR reporting. It does not. The deferral under Article XVIII covers income tax on undistributed gains. The FBAR is a separate disclosure obligation under the Bank Secrecy Act. Treaty deferral + FBAR reporting: both apply simultaneously.
4. Filing the FBAR with the IRS instead of FinCEN. The FBAR goes to FinCEN via the BSA E-Filing System — not to the IRS with your 1040. Form 8938 goes to the IRS. They are different forms filed with different agencies. Sending the FBAR to the IRS does not satisfy the filing requirement.
5. Using year-end balance instead of maximum value. The FBAR requires the highest value during the calendar year, not the December 31 balance. If your RRSP peaked at C$120,000 in September but ended the year at C$95,000, you report C$120,000 converted to USD.

The Bottom Line

The FBAR is a US filing, not a Canadian one. If you are a US person — citizen, green-card holder, or substantial-presence resident — and your foreign financial accounts exceed US$10,000 in aggregate at any point during the year, file FinCEN 114 electronically through the BSA E-Filing System by April 15 (or October 15 under the automatic extension). The penalty for not filing can exceed the account balance within a few years.

If you are a pure Canadian with no US person status, the FBAR does not apply to you. Your US bank and brokerage accounts are reported to the CRA on Form T1135 if their total cost exceeds CAD $100,000. Different country, different form, different threshold — but the same underlying obligation: tell your government about money held abroad.

If you're a dual citizen or former green-card holder and you're unsure whether you qualify as a US person, assume you do until a cross-border tax specialist confirms otherwise. The cost of filing when you didn't need to is zero. The cost of not filing when you should have is up to US$10,000 per account per year — and that's the lenient scenario.