Foreign & information reporting: the forms people miss
Information returns report assets and ownership, not just income — and the penalties for missing them are per-form, per-year, and often standalone. If you have accounts, investments, or entities on the other side of the border, some of these almost certainly apply to you.
U.S. side — for U.S. persons (citizens, residents, green card holders)
- FBAR (FinCEN Form 114) — foreign bank and financial accounts exceeding US$10,000 in aggregate at any point in the year. Threshold is combined, so several modest Canadian accounts can trigger it.
- Form 8938 (FATCA) — specified foreign financial assets over thresholds that depend on filing status and residence.
- Form 3520 / 3520-A — foreign trusts and large foreign gifts or inheritances. Canadian RESPs and certain estate structures can fall here.
- Form 5471 — ownership or control of a foreign corporation (e.g., a Canadian operating company owned by a U.S. person).
- Form 8865 — foreign partnerships.
- Form 8621 — PFICs. Canadian mutual funds, ETFs held in non-treaty-protected structures, and TFSAs holding such funds frequently generate PFIC exposure. Default "excess distribution" taxation is punitive; QEF or mark-to-market elections change the outcome dramatically.
Canadian side — for Canadian residents
- T1135 (Foreign Income Verification Statement) — foreign property costing over C$100,000: U.S. brokerage accounts, U.S. rental real estate, foreign shares held outside registered plans. Not required for U.S.-situated registered plans like a 401(k) or IRA under administrative policy, but reportable property must be identified carefully.
- T1134 — foreign affiliates: a Canadian resident's interest in a foreign corporation or partnership (e.g., a U.S. LLC or corporation held personally).
- Corresponding U.S. information forms often run in parallel — one investment commonly appears on both the Canadian and U.S. lists, with different thresholds and definitions.
How we handle it
We inventory your accounts and entities once, map every item to every form it triggers on both sides of the border, prepare the filings with consistent values, and set up a repeating schedule so nothing is missed next year. If you have discovered missed filings, we also assess whether streamlined or voluntary-disclosure routes are appropriate before simply filing late.
Unsure which forms apply to you?
List your accounts and entities, and we will map them to both countries' requirements.
Contact us