If you are a US citizen or green card holder living in Canada, you file in both countries: a Canadian return because you live here, and a US return because the United States taxes its citizens wherever they live. This guide lists what I review with US citizens in Toronto, ON, with links to the IRS, FinCEN, and CRA pages so you can confirm each point. It is general information, not advice for your situation.
Key dates for the 2026 tax year
- April 15, 2027: Form 1040 is due, and any US tax owing is due by this date. FBAR (FinCEN Form 114) is also due. (IRS: US citizens and resident aliens abroad)
- April 30, 2027: Canadian T1 return and any balance owing (June 15, 2027 to file if you or your spouse or common-law partner are self-employed; the balance is still due April 30).
- June 15, 2027: automatic 2-month extension to file Form 1040 if you live outside the United States on April 15. Interest on unpaid US tax still runs from April 15. (IRS: automatic 2-month extension)
- October 15, 2027: extended due date for Form 1040 if you file Form 4868 in time, and the automatic extended due date for the FBAR.
1. You file in both countries
- US citizens and resident aliens report their worldwide income on a US return, even if they live in Canada and all their income is Canadian. (IRS: US citizens and resident aliens abroad)
- As a resident of Canada, you also report your worldwide income on your Canadian T1 return.
- The Canada-US tax treaty has a "saving clause" (Article XXIX(2)): the US can generally tax its citizens as if the treaty did not exist, with listed exceptions. So the treaty rarely removes the US filing, but it does help decide which country gives the credit. (IRS Publication 597)
2. Avoiding double tax: foreign tax credits
- On the Canadian side, you can generally claim a foreign tax credit for income or profit taxes paid to another country on income you reported in Canada, with Form T2209 (federal, line 40500) and Form T2036 (Ontario). (CRA: line 40500)
- On the US side, you claim a credit for Canadian income tax with Form 1116. You cannot claim it on income you exclude with the foreign earned income exclusion. (IRS: foreign tax credit)
- For US citizens resident in Canada, the treaty has special credit rules in Article XXIV(3) to (5), for example for US-source dividends and interest. Which country gives the credit first depends on the type and source of the income. (IRS Publication 597)
- Because Canadian tax rates are often higher than US rates, many US citizens in Canada owe little or no US income tax, but they still have to file. This depends on your income, so I check it each year.
3. FBAR: reporting your Canadian accounts to FinCEN
- If the total of your financial accounts outside the US (bank, investment, many registered plans) was more than US$10,000 at any time in the year, you file FinCEN Form 114, the FBAR. (IRS: FBAR)
- It is filed online through the BSA E-Filing System, not with your tax return. It is due April 15, with an automatic extension to October 15.
- Keep the records behind each FBAR for 5 years.
4. Form 8938 (FATCA)
- Form 8938 is filed with your Form 1040 and overlaps with the FBAR, but the thresholds are higher. For a taxpayer living abroad, it applies if specified foreign financial assets are more than US$200,000 at year end or US$300,000 at any time (single), or US$400,000 and US$600,000 (married filing jointly). (IRS: Form 8938 and FBAR compared)
- Filing one does not replace the other. If you meet both tests, you file both.
5. RRSP, RRIF, TFSA, and RESP
- Under Revenue Procedure 2014-55, an eligible individual is treated as having elected under the treaty (Article XVIII(7)) to defer US tax on income earned inside an RRSP or RRIF until it is paid out. Form 8891 is no longer used, and Forms 3520 and 3520-A are not needed for these plans. (IRS: Internal Revenue Bulletin 2014-44)
- Rev. Proc. 2014-55 does not change the FBAR or Form 8938: RRSP and RRIF accounts are still reported there.
- The treaty deferral covers retirement plans. A TFSA or RESP is not covered by it, and the US treatment of those accounts depends on the facts. Ask me before you open one or when you report one.
6. Canadian reporting of US property (Form T1135)
- If, at any time in the year, the total cost of your specified foreign property (for example US bank or brokerage accounts, US shares, a US rental property) was more than CA$100,000, you file Form T1135 with your Canadian return. (CRA: questions and answers about Form T1135)
- Property held in an RRSP or TFSA, and personal-use property such as a vacation home you use yourself, is not reported.
- You do not file T1135 for the year you first became resident in Canada.
7. If you are behind on US filings
Many US citizens in Canada learn about these rules late. The IRS has procedures for people whose failure to file was not wilful, and the right route depends on your facts. Do not file amended or late returns without a plan; book a call and we will review your years first.
Checklist
- Canadian T1 return filed by April 30, 2027 (June 15 if self-employed)
- Form 1040 filed by June 15, 2027 (automatic extension), or by October 15, 2027 with Form 4868
- US tax, if any, paid by April 15, 2027 to stop interest
- Foreign tax credits on both returns match (T2209 and T2036, Form 1116)
- FBAR filed if foreign accounts were over US$10,000 at any time
- Form 8938 filed if you meet the higher thresholds
- T1135 filed if your foreign property cost over CA$100,000 at any time
Next step
I prepare US federal individual returns (Form 1040 and 1040-NR) together with your Canadian return, so both sides match. My Canada-US cross-border service page lists what is included. Book a call and bring your last Canadian and US returns.
This guide is general information based on IRS, FinCEN, and CRA pages available in October 2026. It does not replace advice for your situation. Thresholds, forms, and due dates change; check the linked pages or ask me before you act.