Free to start with an on-screen summary — you pay only to generate the package.
Check the common Canada products
Pick every one that applies. Each gets its own read — what the US sees inside the wrapper, and which form it points at.
Free, no account, nothing you answer leaves this page. Open the full portfolio scanner
A screen from the product type. Whether a specific fund is a PFIC turns on its own annual facts; whether a wrapper is a trust or a pension for US purposes turns on its documents.
What actually applies
| Form | What it is | What makes it bite in Canada |
|---|---|---|
| Form 1040 | The US federal return, on worldwide income. | Filed regardless of Canadian residence. Canada runs on the calendar year too, so the periods line up — one of the few things that is genuinely simpler here than in the UK. |
| Form 1116 | Foreign Tax Credit for foreign income tax paid. | Federal plus provincial tax usually exceeds US tax on the same employment income. Quebec's federal abatement reconciles separately. |
| FinCEN 114 (FBAR) | Report of non-US financial accounts once the combined peak exceeds $10,000. | Chequing, savings, a TFSA, an RRSP, a non-registered brokerage account. Registered status is a CRA concept; the FBAR aggregates them all regardless. |
| Form 8938 | FATCA reporting of specified foreign financial assets, filed with the return. | Higher thresholds than the FBAR — from $200,000 year-end for a single filer abroad — but a broader class of assets. |
| Form 3520 / 3520-A | Reporting for foreign trusts and certain foreign gifts. | The reason a TFSA and an RESP are harder than they look: both are commonly treated as foreign grantor trusts for US purposes. An RRSP is not in this bucket. |
| Form 8621 | One per PFIC per year, subject to the form's own triggers. | Canadian mutual funds and TSX-listed ETFs held in a TFSA, an RESP or a non-registered account. Funds inside an RRSP or RRIF stay outside the annual analysis while the Article XVIII deferral holds — the wrapper, not the fund, decides it. |
| Form 8833 | Disclosure of a treaty-based return position that overrides the default treatment. | Not needed for the ordinary Form 1116 credit. Article XVIII positions on retirement plans are the usual reason it comes up. |
| Streamlined (Form 14653) | The catch-up route for non-willful taxpayers living abroad. | A well-worn path for the very large dual-citizen population across Toronto, Vancouver and Montreal. |
A form listed here does not mean it applies to you. Which of these your return needs depends on your accounts, holdings and income.
Three plans, three answers
Article XVIII(7) of the 1980 convention provides for an election to defer US tax on income accruing inside the plan, and Rev. Proc. 2014-55 made that deferral automatic for eligible individuals — which is why Form 8891 is no longer filed.
Deferral is not exemption. The account is still reported on the FBAR and, above the thresholds, on Form 8938, and distributions are taxable when they come out.
The CRA's tax-free status is a domestic rule the convention does not extend to. Income and gains inside a TFSA are generally currently taxable on a US return.
On top of that, the arrangement itself is commonly treated as a foreign grantor trust for US purposes — Form 3520 and 3520-A territory — and the funds inside raise the PFIC question independently.
An RESP raises the same threshold question — is it a foreign grantor trust? — but it is not in the same position as a TFSA. Rev. Proc. 2020-17 exempts trusts operated exclusively or almost exclusively for educational benefits, with withdrawals conditioned accordingly and contributions inside its limits. An RESP is a plausible candidate on those terms; a TFSA, which restricts neither purpose nor withdrawals, is not.
The safe harbour is reporting relief under §6048, not a blanket US income-tax exemption. The Canada Education Savings Grant and the plan's earnings still require a separate US tax analysis, including who is treated as owner. Classification turns on the plan's own documents, so this is a question to answer, not to assume.
Whether a specific plan is a foreign trust for US purposes is a fact-and-documents question, not a rule that applies uniformly. What is reliable is that the three plans are not interchangeable, and that assuming the RRSP answer covers the other two is how this goes wrong.
If you hold Canadian funds
It is the standard Canadian financial advice and, for a US citizen, a standard PFIC problem. Questrade, Wealthsimple and the big-bank brokerages sell Canadian mutual funds and TSX-listed ETFs, and each is a non-US pooled vehicle — generally one Form 8621 per fund per year in a TFSA, an RESP or a non-registered account. Funds inside an RRSP or RRIF are the exception: while the Article XVIII deferral holds, they stay outside the annual analysis.
Unlike the EU, Canada has no PRIIPs rule keeping US-listed ETFs off the retail shelf, so a US-domiciled fund is genuinely available here — and a US-domiciled fund is not a PFIC. Direct shares in Royal Bank or Canadian National are not PFICs either, and neither is a GIC.
Two more Canada-only wrinkles
Canada's principal residence exemption can eliminate the Canadian tax on a home sale gain entirely. The US has no equivalent — only the §121 exclusion, which is capped and carries its own ownership and use tests.
A gain fully sheltered in Canada can therefore be partly taxable in the US, and because no Canadian tax was paid on it, there is nothing to credit against the result.
Canada has one of the largest populations anywhere of people who are US citizens by birth and have lived their entire adult lives somewhere else. The filing obligation follows the citizenship rather than the residence.
It is a common situation with established routes back into compliance — worth understanding calmly rather than urgently.
Investment income · the 3.8%
Canadian tax on dividends, gains and a property sold credits against your regular US tax on Form 1116 — and, since the Federal Circuit's Bruyea decision of August 31, 2026, against nothing else. Above $200,000 of MAGI (single) or $250,000 (joint), the net investment income tax reaches the same income with no credit at all — including the TFSA income Canada exempts.
Check it for your own income
Four banded answers, no figures typed, no email. The read says which side of the threshold you sit on and — if you paid tax abroad — what that credit can and cannot do.
Free, no account, nothing you answer leaves this page. Open the full NIIT Exposure Check
A banded screen for a US citizen or resident; Form 8960 settles the exact figure. Four answers give bands for net investment income and MAGI, and no read here nets a foreign tax credit against the 3.8% — the Code allows none.
Free tool · no account
Pick your broker — Questrade, Wealthsimple, RBC Direct Investing, IBKR — and what you hold, or paste the ISINs from your statement.
Result
Tell us what you hold
Pick the closest match on the left, or paste your ISINs below and we'll flag each one.
More for US taxpayers in Canada: The Canada desk.
Educational estimate, not tax advice. Domicile is the fund's legal home, not the broker or exchange you used. Broker and provider policies change — confirm current terms with your provider before acting.
Free scanner · no account
Whole portfolio? Drop in the positions export from Questrade, Wealthsimple or your bank and every holding is screened at once — with the TFSA, RRSP and FHSA questions the account raises.
Upload my statementCatch-up · Canada
A US citizen or green-card holder living in Canada who has not filed US returns or FBARs can usually come current through a published IRS route rather than a penalty case. Which route depends on whether returns were filed at all, whether the failure was non-willful, and what Canadian accounts and investments the open years contain. Nothing is counting down — no IRS-announced end date is currently published.
What changes a submission from Canada
Canadian bank accounts, a TFSA, an RRSP, an RESP and a RRIF are all foreign financial accounts for the FBAR even when their income is deferred; a Canadian mutual fund or ETF held outside an RRSP adds a Form 8621 to every open year.
Accounts readers here usually have to count: Chequing and savings · TFSA · RRSP / RRIF · RESP.
Programme status
Active — no announced end date
Verified against the IRS instructions and the IRM on October 6, 2026. Is the Streamlined procedure ending?
The eligibility check is free and screens the published gates; the case assessment is the paid, per-year review that names the forms and deadlines for your own years.
Behind on filings?
A qualifying taxpayer files the most recent 3 years of returns and the most recent 6 years of FBARs, with the offshore penalty at 0%. Two gates: non-willful conduct, and the non-residency test — no US abode and at least 330 full days outside the United States, in at least one of the last three years for which the return due date has passed.
On Canadian employment income, the tax across those years is often little or nothing after the credit for Canadian tax. The volume is in the information returns — a TFSA and an RESP held for several years can produce Form 3520 and Form 8621 obligations across the whole window.
You certify non-willfulness on Form 14653, under penalty of perjury. Atamatax prepares the return side; you write the certification in your own words, assemble the mailing from the package's instructions, and file.
The treaty, in short
US–Canada Convention 1980
The most-amended US treaty in force. It allocates taxing rights and provides relief from double taxation under Article XXIV — for a US citizen, almost always as a credit on Form 1116. The saving clause preserves US taxation of its own citizens subject to the exceptions the convention lists.
The Canada treaty desk does the article-level work, including how the RRSP deferral actually resolves. This page exists for the broader question of what living in Canada does to a US return.
Toronto has its own guide too, for city-level detail on Bay Street employers and equity compensation.
The Canada desk
The TFSA and US tax: why “tax-free” stops at the border
A TFSA is the most-recommended savings account in Canada and one of the worst places for a US citizen to hold anything. Canada exempts it; the United States does not recognise the wrapper at all.
RRSPs and US tax: the deferral is automatic, the reporting is not
The RRSP is the one Canadian wrapper the United States genuinely respects. Since 2014 the deferral is automatic and Form 8891 is gone — which is exactly why people now under-report it.
The FHSA and US tax: a first-home account the IRS has never heard of
Canada's First Home Savings Account gives you an RRSP-style deduction going in and a TFSA-style tax-free withdrawal coming out. A US citizen gets neither: no deduction, income taxed as it arises, and an open question about whether the account is a foreign trust.
Canadian mutual funds, ETFs and the PFIC rules
A TSX-listed ETF is the most ordinary thing a Canadian investor can own, and one of the clearest PFIC cases there is. What changes the outcome is not the fund — it is which account it sits in.
Wealthsimple for US citizens: what the account holds, and what the IRS sees
Wealthsimple will open an account for a US citizen living in Canada — and then, by default, fill it with the two things the IRS treats worst: a Canadian-listed ETF, and a TFSA to hold it in. Here is how to read your own account before you file.
Questrade for US citizens: one account, PFICs and non-PFICs side by side
Questrade gives a US citizen in Canada access to both the TSX and the US exchanges — which is exactly why it is the broker where a portfolio most often ends up half PFIC and half not. The listing decides, not the broker.
The RESP and US tax: the government grant is the surprise
Canadian parents are told to open an RESP for the 20% grant. For a US-citizen subscriber, that grant is income — and the account it lands in gets no US recognition at all.
FBAR for Americans in Canada: which accounts count, and when
Almost every US citizen in Canada crosses the FBAR threshold, usually without noticing. A chequing account, an RRSP and a TFSA together clear it easily — and registered accounts count exactly like the rest.
Catching up from Canada: the Streamlined Foreign Offshore Procedures
Canada has more accidental Americans than anywhere else — people who left as children, or never lived there at all. The Streamlined procedure exists for exactly that situation, and its first test is about where you live.
Investment tax for Americans in Canada: the TFSA, the RRSP, the ETFs and the 3.8%
One page for a US citizen in Canada who holds Canadian accounts: which US forms each wrapper raises, which funds are PFICs, what the Canadian tax you paid does and does not offset, and how Atamatax prepares it.
Do Americans in Canada pay the net investment income tax?
Yes, above the threshold — and the Canadian tax you paid reduces your regular US tax, not the 3.8%. The TFSA, the non-registered account, the RRSP and a property sold, each against §1411, with Bruyea on the credit line.
Capital gains for Americans in Canada: half-inclusion, the principal-residence exemption, and the US return
Canada includes half of a gain and exempts a home entirely; the United States includes all of it, in dollars, shelters $250,000 of a home, and adds 3.8% above the threshold. How the two systems meet on a sale.
Estate of Bruyea v. United States: the Canada treaty and the NIIT
U.S. Court of Appeals for the Federal Circuit, No. 25-1563, decided August 31, 2026. A US citizen in Canada sold Canadian real estate, paid Canada, and claimed Article XXIV against the 3.8%. The trial court agreed; the Federal Circuit reversed. What it held, who it reaches, what it left alone.
U.S. Tax Filing for Americans in Toronto
Fixed-fee support for U.S. citizens, Green Card holders and dual nationals in Toronto — TFSA and RRSP, Canadian funds, FBAR and FATCA reporting.
Canada · US treaty desk
The 1980 convention and its protocols, article by article.
Form 3520 & 3520-A: foreign trusts
The reporting a TFSA or RESP commonly pulls in.
PFICs and Form 8621
What a Canadian mutual fund or TSX-listed ETF does to a US return.
FBAR & Form 8938 threshold checker
Test your Canadian account balances against both thresholds.
Accidental Americans & dual citizens
US citizenship by birth, and what it means decades later.
All country desks
US filing abroad, adapted to where you live.
Guides for US taxpayers in CanadaRelated
The layers a US return runs through don't change by country — what changes is which local accounts, funds and pensions actually trigger them. Here's how Canada compares.
Canadian accounts, US rules, one plan: the Express Plan orders the filings a TFSA, an RRSP and Canadian funds trigger, with the documents to gather for each, before you start a return.
Primary sources (Cornell Legal Information Institute for the US Code and CFR; IRS.gov for forms, procedures, and treaty documents). This page is general information, not individualized tax or legal advice.
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Scan your registered and non-registered holdings, see your PFIC count, check your FBAR and Form 8938 thresholds, and get the forms your return needs. You pay only to generate the package.