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Cross-Border Tax (U.S.–Canada)

U.S. Citizens Living in Canada: What You File Each Year

The U.S. return, the credits, the account reports, the forms Canadian accounts trigger, and the deadlines

Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks

A U.S. citizen living in Canada files a U.S. return every year on worldwide income, because the United States taxes citizens wherever they live. The foreign tax credit usually eliminates U.S. tax on Canadian income, but the filings remain: the return, the FBAR, often Form 8938, and forms triggered by Canadian funds and companies.

On this page
  1. The annual list
  2. Things that trip people up
  3. Frequently asked questions
  4. Related guides
  5. Official sources
  6. Next step

The annual list

FilingWhen it appliesDeadline
Form 1040Gross income above the filing thresholdJune 15 (automatic two-month extension for those living abroad — interest on unpaid tax still runs from April 15), extendable to October 15 with Form 4868
Form 1116Claiming credit for Canadian taxWith the return
FBARForeign accounts above US$10,000 aggregateApril 15, automatic extension to October 15
Form 8938Foreign assets above US$200,000 single / US$400,000 joint on the last day of the year, or US$300,000 / US$600,000 at any time (abroad thresholds)With the return
Form 8621Canadian mutual funds or ETFs outside registered plansWith the return
Form 547110 percent or more of a Canadian corporationWith the return
Form 3520Canadian trust distributions, large foreign giftsWith the return
Canadian T1Canadian residentApril 30 (June 15 if self-employed)

Things that trip people up

TFSAs (not recognized by the U.S. — income taxable, possible trust reporting — the TFSA vs Roth guide), Canadian mutual funds (PFICs — the PFIC guide), RESPs (the U.S. doesn't recognize the plan's tax deferral, so plan income — and, on the common treatment, the Canada Education Savings Grant — is taxable to a U.S.-citizen subscriber; the IRS has issued no RESP-specific guidance), the principal residence sale (the U.S. §121 exclusion is US$250,000 single / US$500,000 joint and isn't indexed, while Canada's principal residence exemption can shelter the whole gain — so gain above the U.S. exclusion can be U.S.-taxable with no Canadian tax to credit), and the Canadian corporation (a CFC — the Form 5471 guide).

Frequently asked questions

Do U.S. citizens in Canada have to file U.S. taxes?

Yes — on worldwide income, every year, if income exceeds the filing threshold.

Will I owe U.S. tax?

Often not — the foreign tax credit for Canadian tax usually covers it, but PFICs, TFSAs, and home sales can create U.S. tax.

When is the U.S. return due for someone living in Canada?

June 15 automatically (attach a statement; interest on any unpaid tax runs from April 15), with an extension to October 15 available on Form 4868.

What if I've never filed?

The streamlined foreign offshore procedures usually allow catching up on three years of returns and six of FBARs without penalties.

Official sources

The IRS explains: “File Form 1116 to claim the foreign tax credit if you are an individual, estate, or trust, and you paid or accrued certain foreign taxes to a foreign country or U.S. possession.” — Internal Revenue Service, About Form 1116, Foreign Tax Credit (Individual, Estate, or Trust), https://www.irs.gov/forms-pubs/about-form-1116

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

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 annual U.S. returns, FBARs, and international information returns for U.S. citizens living in Canada. 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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