A US citizen living in Canada with investment accounts on both sides of the border can face three separate disclosure filings in one year — one to the Canada Revenue Agency, one to the US Treasury’s financial crimes unit, and one to the IRS.

Not three copies of the same form. Three different regimes that define “foreign,” “account,” and “how much is too much” in three different ways.

The same word means three different things

“Foreign” depends on who’s asking. For Canada’s T1135, foreign means outside Canada — a US brokerage account is foreign property. For the US filings, foreign means outside the US — the Canadian chequing account is the foreign one. A dual filer’s entire portfolio is “foreign” to somebody.

What counts differs. The FBAR is about financial accounts — bank, brokerage, and certain others — regardless of what’s inside them. Form 8938 casts a wider net over specified foreign financial assets, which can capture things that aren’t accounts at all. The T1135 covers specified foreign property, a category that can reach assets neither U.S. form captures, including certain non-personal-use foreign real estate. The three nets overlap heavily but none is a subset of another.

The thresholds don’t match. Each regime has its own dollar trigger, in its own currency, measured its own way — some against a peak value during the year, some against year-end, with the US thresholds varying by filing status and by whether the filer lives abroad. The specific figures are deliberately not printed here because each regime has its own threshold, currency, and measurement method; the important point is that one threshold tells you nothing about the others. It is routine to owe one filing and not the others.

Even the destination differs. The T1135 goes to CRA with the Canadian return. Form 8938 attaches to the US return. The FBAR doesn’t go to the IRS at all — it’s filed separately, to FinCEN, through its own electronic system, a distinction with real consequences covered in The FBAR Isn’t Part of Your Tax Return: Where It Actually Gets Filed.

Why “I already reported that” is the expensive sentence

Each regime penalizes its own omissions independently. Disclosing an account on the FBAR does not satisfy Form 8938; reporting it to CRA satisfies neither. A filer who diligently completes two of the three filings and skips the third hasn’t reduced the exposure on the third by one dollar.

The pattern that produces trouble is rarely concealment. It’s a dual filer who reasonably assumes the paperwork must be redundant — that governments this interested in the same accounts surely share a form. They don’t. The broader US disclosure system and its penalty structure is mapped in The Second Filing System: US Disclosure Forms Most Expats Never Hear About; the T1135 sits alongside it as Canada’s parallel answer.

The practical takeaway is a habit, not a rule: when accounts cross the border, the question is never “did I report this?” It’s “did I report this to everyone whose definition it meets?” Three regimes, three checklists — checked separately, every year.

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