U.S. tax filing · Toronto
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
Published June 2026 · Updated July 2026
Part of the Canada desk — every US tax topic for Canada in one place.
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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.
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.