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.

By Danilson Ramos · Founder, Atamatax

Updated July 2026

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Toronto has a large American and dual-national community across finance, tech, healthcare and academia, including many who have lived in Canada for years. Canada and the U.S. have a comprehensive tax treaty, but several everyday Canadian savings accounts are treated very differently by the IRS than by the CRA.

Typical situations we see in Toronto

TFSAs: tax-free in Canada, but the U.S. generally does not recognise the shelter and may treat it as a foreign trust, which can mean additional filings (potentially Forms 3520 and 3520-A).
RRSPs: the U.S.–Canada treaty generally allows deferral of U.S. tax on growth, but reporting still applies and the election matters.
Canadian mutual funds and ETFs held in non-registered or TFSA accounts that may be PFICs (Form 8621).
Dual U.S.–Canada citizens who have lived in Toronto for years and are catching up on U.S. filings.
Multiple Canadian bank and investment accounts that together cross the FBAR threshold.

A TFSA is tax-free in Canada, but for a U.S. person it can be one of the trickier accounts — the IRS may not recognise the shelter and may treat it as a foreign trust with extra reporting. It is generally worth reviewing before filing.

TFSA and RRSP, treated differently

RRSPs generally benefit from treaty-based deferral of U.S. tax on internal growth, while TFSAs often do not get equivalent treatment and can carry foreign-trust reporting. Canadian funds inside either account may also be PFICs. Getting the reporting right helps avoid costly missed forms. Atamatax provides preparation support; this is not individualized advice.

Authorities cited

IRS Form 3520 — About Form 3520 — Annual Return To Report Transactions With Foreign Trusts
IRC §6048 — IRC §6048 — Information reporting for foreign trusts (Forms 3520 / 3520-A)
IRC §1291 — IRC §1291 — Interest on tax deferral (excess-distribution regime)
IRC §1297 — IRC §1297 — Definition of a passive foreign investment company
IRS Form 8621 — About Form 8621 — Information Return by a Shareholder of a PFIC or QEF
31 CFR §1010.350 — 31 CFR §1010.350 — FBAR (FinCEN Form 114) filing requirement and $10,000 threshold
FinCEN Form 114 (FBAR) — Report of Foreign Bank and Financial Accounts (FBAR)

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.

Atamatax provides tax preparation support and educational resources. This website does not constitute legal or tax advice.

Frequently asked questions

Is my TFSA a problem for U.S. taxes?

The U.S. generally does not treat a TFSA as tax-free and may view it as a foreign trust, which can require additional filings such as Forms 3520 and 3520-A, and any funds inside may be PFICs. Many dual citizens in Canada review their TFSAs carefully. This is informational, not individualized advice.

How is my RRSP treated for U.S. taxes?

The U.S.–Canada treaty generally lets you defer U.S. tax on income that builds up inside an RRSP, but reporting still applies and the relevant election matters. It is worth confirming your RRSP is handled correctly rather than assuming.

Do Americans in Toronto still need to file U.S. taxes?

In most cases yes — the U.S. taxes citizens and Green Card holders on worldwide income regardless of where they live. Foreign tax credits and exclusions often reduce or eliminate the U.S. tax owed, but reporting (including the FBAR) can still be required.

Does Atamatax work with people based in Toronto?

Yes. Atamatax provides fixed-fee U.S. tax filing support for U.S. citizens and Green Card holders living abroad, including Toronto. The final quote depends on your documents and tax situation.