First-Year FBAR and Form 8938 for New U.S. Residents
Which Canadian accounts to report in the first U.S. year, the thresholds, and the dual-status rules
Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks
A Canadian who becomes a U.S. resident must start reporting Canadian accounts: the FBAR if all foreign accounts exceed US$10,000 in total at any time in the year, and Form 8938 above higher thresholds. The first year is usually a dual-status year, and the FBAR covers the whole calendar year once you're a U.S. person.
On this page
First-year rules
| Item | Rule |
|---|---|
| FBAR | Required if you're a U.S. person at any time in the year and the aggregate maximum value exceeds US$10,000 — FinCEN's instructions value each account at its highest point during the calendar year and contain no split-year exception, so the dual-status year is reported in full |
| Form 8938 | Required for the resident portion of a dual-status year (the reporting period is the part of the year you're a resident) if thresholds are met; thresholds for U.S. residents are more than US$50,000 at year-end or US$75,000 at any time (single; US$100,000/US$150,000 married filing jointly) (the Form 8938 guide) |
| RRSPs, RRIFs, TFSAs | Reportable on both (the FBAR guide) |
| Canadian funds | PFIC reporting on Form 8621 (the PFIC guide) |
| Canadian corporation | Form 5471 if a shareholder (the Form 5471 guide) |
Avoiding first-year problems
Sell Canadian mutual funds and withdraw the TFSA before the residency start date (the pre-immigration guide); keep year-end and maximum balances for every account from January 1; and note the residency start date in your records.
Frequently asked questions
Do I file an FBAR in my first U.S. year?
Yes, if your foreign accounts exceeded US$10,000 in aggregate at any time during the year and you were a U.S. person for part of it.
Do I report my RRSP?
Yes — on the FBAR and on Form 8938 if thresholds are met.
Is Form 8938 required for a dual-status year?
For the resident portion, if you meet the thresholds.
What should I do before becoming a resident?
Withdraw the TFSA and replace Canadian mutual funds to avoid complex reporting.
Official sources
FinCEN explains: “A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.” — Financial Crimes Enforcement Network, Report Foreign Bank and Financial Accounts, https://www.fincen.gov/report-foreign-bank-and-financial-accounts
The IRS explains: “Use Form 8938 to report your specified foreign financial assets if the total value of all the specified foreign financial assets in which you have an interest is more than the appropriate reporting threshold.” — Internal Revenue Service, About Form 8938, Statement of Specified Foreign Financial Assets, https://www.irs.gov/forms-pubs/about-form-8938
Next step
Fairlight Accounting is a cross-border accounting and tax practice with a U.S. Tax Desk and a Canadian Tax Desk. Our U.S. Tax Desk and Canadian Tax Desk handle first-year FBAR, Form 8938, and international information return setup for new U.S. residents. See pricing or book a call.
Cross-border taxes, handled in one place
U.S. and Canadian filings prepared together by our U.S. and Canadian Tax Desks.
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