I'm a Dual US-Canada Citizen and Have Never Moved. What Do I File?

You do not need to move between countries to have cross-border tax obligations. If you are a dual US-Canada citizen who was born with both citizenships (or acquired one through a parent), the filing obligations exist from the moment you have income, and they are permanent. The US taxes its citizens on worldwide income regardless of where they live. Canada taxes its residents on worldwide income regardless of their citizenship. If you are a dual citizen living in Canada, you owe both countries a return every year. If you are a dual citizen living in the US, you owe the US a return (obviously) and generally do not owe Canada a return (because Canada taxes based on residency, not citizenship), unless you have Canadian-source income.

The distinction matters because the most common version of this question comes from dual citizens who have lived in Canada their entire lives and have never filed a US return. The filing obligation existed all along.

Dual citizen living in Canada

This is the more common and more complex scenario. You hold both citizenships. You live in Canada. You have always lived in Canada. You work for a Canadian employer, have Canadian bank accounts, an RRSP, maybe a TFSA, and Canadian investments.

Canadian obligations (these are straightforward): file a T1 return reporting worldwide income, pay Canadian tax. This is what you have always done.

US obligations (these are the ones people miss):

1. Form 1040 (US income tax return). Report your worldwide income in US dollars. Claim the foreign tax credit (Form 1116) for Canadian tax paid. Because Canadian tax rates exceed US rates at most income levels, the FTC usually eliminates all US tax. You owe nothing, but you still file.

2. FBAR (FinCEN 114). If the aggregate balance of all your non-US financial accounts exceeds $10,000 at any point during the year, file the FBAR. For a Canadian resident, this includes every bank account, savings account, RRSP, TFSA, RESP, RDSP, non-registered brokerage account, and any other account at a Canadian financial institution. The threshold is low, and most Canadian adults exceed it. Filed electronically through the BSA E-Filing System. Due April 15 with automatic extension to October 15.

3. Form 8938 (FATCA). If your specified foreign financial assets exceed the threshold ($200,000 at year-end or $300,000 at any point during the year, for taxpayers living abroad filing single; $400,000/$600,000 for MFJ), file Form 8938 with your 1040. The assets overlap with FBAR but the thresholds and reporting details differ. See the 8938 vs FBAR guide for the comparison.

4. Form 3520/3520-A. If you have a TFSA, the US treats it as a foreign trust. You must file Form 3520 annually, and the TFSA trust must file Form 3520-A. The penalties for non-filing are severe ($10,000 minimum per form per year). This is one reason US citizens in Canada should not open a TFSA.

5. Form 8621. If you hold Canadian mutual funds or Canadian-listed ETFs in a non-registered account, each one is a PFIC. File Form 8621 for each PFIC holding, each year.

6. Form 8891/treaty election. If you have an RRSP, make the Article XVIII(7) treaty election to defer US taxation on the RRSP income. This election is now reported as part of the regular return (Form 8891 was discontinued, but the election is still claimed).

The typical dual citizen in Canada who earns $80,000 CAD from employment, has a bank account, an RRSP, and no TFSA or Canadian mutual funds, files: 1040 + Form 1116 + FBAR + possibly Form 8938. Owes zero US tax. The filing is a compliance exercise, not a tax-paying one.

What if I have never filed a US return?

Many dual citizens living in Canada discover their US filing obligation later in life. This is common for people who acquired US citizenship at birth through a parent but grew up entirely in Canada.

The IRS Streamlined Filing Compliance Procedures are designed for this situation. You file 3 years of delinquent 1040s and 6 years of delinquent FBARs, certify that your failure to file was non-willful, and pay any tax owed (usually zero, because the FTC covers it). No penalties if you qualify.

The streamlined procedures are the standard path for dual citizens who are coming into compliance for the first time. The process is well-established, and for someone with straightforward Canadian employment income and standard accounts, it is not complicated.

Dual citizen living in the US

This is simpler. You live in the US. You are both a US citizen and a Canadian citizen.

US obligations: file a US return reporting worldwide income. Pay US tax. This is your primary tax home.

Canadian obligations: generally none, unless you have Canadian-source income. Canada taxes based on residency, not citizenship. If you are not a Canadian resident (you live in the US, have no residential ties to Canada), Canada does not tax your worldwide income. You are not required to file a T1 unless you have Canadian-source income (e.g., rental property in Canada, Canadian employment income, Canadian pension or RRSP withdrawals).

If you receive Canadian-source income, Canada may withhold Part XIII tax (25% default, reduced by treaty), and you may need to file a Canadian non-resident return (T1) to report the income and claim any applicable treaty benefits. The US includes the same income and allows an FTC for the Canadian tax.

Maintaining or severing Canadian ties: your Canadian citizenship alone does not make you a Canadian tax resident. CRA determines residency based on residential ties (home, spouse/dependants in Canada, personal property, social ties), not citizenship. A dual citizen living in the US with no residential ties to Canada is not a Canadian tax resident.

The TFSA trap

This deserves its own section because it catches so many dual citizens. A US citizen in Canada who opens a TFSA gets the worst possible outcome: Canada treats the TFSA income as tax-free, the US treats the TFSA as a foreign trust and taxes all income inside it annually, and the reporting burden (Forms 3520, 3520-A) is significant. The “tax-free” account produces US tax and US reporting obligations that make it a net negative.

If you are a dual citizen in Canada and you already have a TFSA, the standard advice is to close it. The TFSA foreign trust guide covers the mechanics and the cost of maintaining vs closing it.

The investment problem

A dual citizen in Canada who invests in Canadian mutual funds or Canadian-listed ETFs in a non-registered account holds PFICs. The PFIC regime taxes gains at the highest rate plus an interest charge. The fix: hold US-listed ETFs in the non-registered account (not PFICs), and use the RRSP for any Canadian-listed holdings (RRSP is shielded from PFIC by the treaty election).

This is not optional planning advice. It is a structural requirement for any dual citizen who invests. Canadian mutual funds in a non-registered account produce punitive US tax outcomes.

What should I do next?

If you are a dual citizen and have been filing in both countries, review your investment structure (TFSA, PFICs) and your FBAR/8938 compliance. If you are a dual citizen who has never filed a US return, the IRS Streamlined program is the standard path. Start by gathering 3 years of Canadian T1 returns and 6 years of financial account statements.

• IRS Streamlined procedures: what do they cost?, the catch-up process
• Form 8938 vs FBAR: do I file both?, the overlapping reporting requirements
• Is a TFSA a foreign trust?, the TFSA problem for US citizens
• What can I invest in without PFIC problems?, the investment restructuring

This guide is general information, not tax advice for your specific situation. Which points apply, and how, depends on your facts.