TL;DR
- An FBAR and FATCA checklist starts with confirming whether you count as a US person.
- FBAR (FinCEN Form 114) reports foreign accounts once the aggregate threshold is crossed.
- FATCA uses Form 8938, filed with the IRS, covering broader financial assets.
- RRSPs and TFSAs generally count as reportable foreign accounts.
- Streamlined filing compliance procedures exist if you have fallen behind.
Tohme Accounting built this FBAR and FATCA checklist for Canadians to untangle their US reporting duties. Samer Tohme, CPA, has guided Ottawa and Toronto clients through cross-border US filing obligations since 2011. This guide previews who actually needs to worry about FBAR and FATCA, how the two forms differ, and a step-by-step first-year checklist you can build into an annual routine.
Who Needs FBAR and FATCA
This FBAR/FATCA checklist for Canadians starts with a single question: are you a US person? These obligations generally attach to US citizens, green card holders, and certain long-term residents, no matter where they currently live. That reach surprises many Canadians with US ties, including those who left the United States years ago or acquired citizenship at birth. If any of those categories describe you, both filing duties may already apply.
What Is FBAR Filing Requirements
Understanding FBAR filing requirements begins with the form itself. FBAR, filed as FinCEN Form 114, reports your foreign bank and financial accounts once their combined aggregate value crosses a published threshold at any point during the year. It goes to FinCEN, not the IRS. Because published figures can change, confirm the current aggregate threshold with FinCEN or a cross-border CPA rather than relying on an unverified online number.
FATCA vs FBAR Differences
FATCA in Canada centers on Form 8938, which is filed with the IRS alongside your annual return. It covers a broader set of foreign financial assets than FBAR, and it has its own separate thresholds that vary by filing status and residency. Because the two regimes measure different things through different agencies, the same accounts can appear on both forms in the same year. Filing one does not satisfy the other.
Quick comparison:
| Feature | FBAR | FATCA |
| Form | FinCEN Form 114 | Form 8938 |
| Filed with | FinCEN | IRS |
| Scope | Foreign accounts | Broader financial assets |
Your First-Year Filing Checklist
The practical FBAR and FATCA checklist for a first year comes down to four steps you can work through in order:
- Inventory every foreign account and record its peak value during the year.
- Review whether prior years should also have been reported.
- Gather account statements early rather than at the deadline.
- Build a recurring annual filing calendar instead of treating this as a one-time task.
Working through these steps up front turns a confusing obligation into a repeatable routine.
Common FBAR FATCA Mistakes
When Canadians file Form 8938 and complete an FBAR, the same missteps repeat year after year. Many filers overlook RRSPs, TFSAs, or joint accounts when calculating the aggregate threshold, then assume a low balance in any single account means no reporting is needed. The threshold looks at your combined total, not one account in isolation. Joint accounts add another layer worth confirming before you file.
If You’ve Fallen Behind
Discovering these duties late is common, and it does not have to be a crisis. The IRS offers streamlined filing compliance procedures for U.S. persons who were genuinely unaware of their filing obligation, providing a defined path to getting current. Acting sooner generally limits your exposure. Because specific penalty figures vary and are reported inconsistently, review your situation with a cross-border CPA before choosing a catch-up route.
RRSPs, TFSAs, and FBAR
For a US person living in Canada, tax reporting includes account types that feel entirely ordinary in Canada. RRSPs and TFSAs are everyday retirement and savings vehicles, yet both generally count as reportable foreign accounts for FBAR and FATCA purposes. That distinction catches many first-time filers off guard, because a registered plan opened through a Canadian bank still sits abroad from the US perspective. Include these balances in your aggregate threshold.
FBAR Within Your Annual Filing
It helps to see where FBAR filing requirements sit in the bigger picture. FBAR and FATCA reporting run alongside, not instead of, the annual cross-border US filing obligations on Form 1040 that US persons abroad must still meet each year. Meeting your account-reporting duties does not replace the income tax return, and completing the return does not cover the account disclosures. All three follow the same annual filing cycle.
Recordkeeping for Future Filings
Filing Form 8938 for Canadians becomes far easier when your records are ready before you sit down. Save year-end and peak-balance statements for every foreign account as they arrive, rather than reconstructing them under deadline pressure. Peak-value tracking matters most, since that figure often drives whether a threshold is crossed. A simple folder, updated as statements come in, pays off across multiple years, much like organized bookkeeping services.
Coordinating Canadian and US Advisors
For a US person living in Canada, tax coverage often involves two sets of hands. FBAR and FATCA sit on the US side of a Canadian resident’s picture, while Canadian filings follow their own rules and calendar. When your Canadian returns and personal tax services stay coordinated with your US side, you avoid gaps and duplicated work. Clear communication between both sides keeps your full picture aligned.
Cross-Border Support From Tohme Accounting
Tohme Accounting, led by Samer Tohme, CPA, has helped Ottawa and Toronto clients navigate FBAR, FATCA, and dual US-Canada filing obligations since 2011. An FBAR/FATCA checklist can point you in the right direction, but every situation has its own mix of accounts and prior years. Samer Tohme works with cross-border clients to clarify what applies to them, drawing on more than a decade of experience with US tax filing for US citizens living in Canada. If your situation involves FBAR and FATCA obligations, schedule a Free Consult with Samer Tohme to clarify what applies to you before you commit to anything.
Conclusion
An FBAR and FATCA checklist for Canadians comes down to a few durable habits: confirm whether you are a US person, inventory your foreign accounts and their peak values, understand how FBAR and FATCA differ in scope and filing authority, and fold the whole process into an annual routine. Treated that way, cross-border reporting stops being a yearly scramble and becomes a manageable, predictable task you revisit each filing season.
FAQs
Do I still need to file an FBAR if I live in Canada?
Yes. Living in Canada does not remove the obligation for US persons. The FBAR requirement follows your citizenship or immigration status, not your physical location. A US citizen or green card holder living in Ottawa or Toronto may still need to file once their combined foreign accounts cross the aggregate threshold at any point during the year, just as they would if they lived in the United States.
Do I have to report my Canadian RRSP on the FBAR?
Generally, yes. An RRSP is treated as a reportable foreign account for FBAR purposes, even though it functions as an ordinary retirement plan in Canada. That means you should count its balance when you calculate whether you’ve crossed the aggregate threshold. Because registered plans surprise many first-time filers, confirm how each account factors into the total before you file.
What is the difference between FBAR and FATCA?
The clearest distinction is where each form goes and what it captures. FBAR is filed with FinCEN and focuses on foreign bank and financial accounts. FATCA is reported on Form 8938, filed with the IRS alongside your annual return, and covers a broader set of foreign financial assets. Thresholds also differ, so the same accounts can appear on both forms in a single year.
Who must file an FBAR?
An FBAR obligation generally applies to US persons, meaning US citizens, green card holders, and certain long-term residents, regardless of where they live. The filing trigger is the aggregate value of your foreign accounts crossing the published threshold at any point during the year. If both conditions describe you, the requirement likely applies, which is why many Canadians with US ties confirm their status before assuming they are exempt.
What should be included in an FBAR?
An FBAR generally captures your foreign financial accounts as a whole, not just chequing accounts. That typically includes foreign bank accounts, investment and brokerage accounts, and certain retirement accounts such as RRSPs. Because the reporting looks at your combined aggregate value, even accounts with modest individual balances may need to be listed once the total crosses the threshold. Reviewing every account you hold prevents overlooked items.
What are FATCA filing requirements?
FATCA filing requirements center on Form 8938, filed with the IRS alongside your annual return when the value of your specified foreign financial assets exceeds the applicable threshold. Those thresholds vary by filing status and residency. Importantly, Form 8938 for Canadians coexists with the FBAR rather than replacing it, so meeting one obligation does not satisfy the other. Both can apply to the same accounts in the same year.
