Reporting RRSP with Form 8938 and FBAR

[serge_lamarre]

Hi,

I hope that someone can help us.

My wife and I are Canadians who now live in Florida since 2006. We have both Canada and US Citizenship. After talking with some friends, it turns out that we need to declare any bank accounts that have more than $10,000 combined to the IRS and Department of the Treasury. We thought that this was only valid for foreign bank accounts but it looks like that this is also applicable to RRSPs as well. We do have RRSPs in Canada (more than $150,000 USD) that we need to declare and file. Those RRSPs are for retirement and we are not getting ANY distribution and not making ANY contributions whatsoever so basically, we do not have any income from our RRSPs.

How should we fill out the Form 8938 and FBAR? Should we fill the form 8938 with our 2024 Tax Return and then fill out the past 6 years with the FBAR? (After reading on FBAR, no need to fill out older than 6 years)

Thank you.

[SusanY1]

Both the FBAR and the 8938 are reporting only forms, though the 8938 does ask if there are any income items from the assets listed on the account.  File your past year FBAR forms directly with FinCEN HERE.  You will use the link for "BSA filing" (not beneficial ownership reporting).  It will ask the reason for the late filing and one of the options allowed is "I didn't know I had to file." 

For the Form 8938, since it is attached to your tax return, you can submit it for prior years by filing an amended return.  I would recommend amending for the prior 3 years.  

Since there aren't any calculations that would change you could also do this relatively easily by hand.  To do that, fill out the 8938 and attach to it only Form 1040X.  You would fill out only the top of the form with your names, SSNs, address, and the tax year for which you are filing an amendment.  Then skip to the bottom and provide the explanation - something like "we are sending Form 8938 for the above year which we only recently became aware we were required to file."   Then mail it to the IRS at the address provided for 1040-X and your resident state HERE.

You can also prepare amended returns in TurboTax as well, of course, using these instructions:

Amend TurboTax Online 

Amend TurboTax CD/Download 

[serge_lamarre]

Thank you for the help,

From the 8938 form perspective, it is well explained.

As far as the FBAR, should I follow the Delinquent FBAR submission procedures explained here below:

https://www.irs.gov/individuals/international-taxpayers/delinquent-fbar-submission-procedures

Also, in what order should it proceed with the steps below. In what order it would make sense from an IRS perspective to avoid any suspicious if any...

- File 2024 Tax Return along with 2024 Form 8938.

- Manually/PDF fill Form 8938 for 2021, 2022 and 2023 along with the correcponding 1040-X and send by mail.

- FBAR and BSA Filling with FinCEN for FYI 2021, 2022, 2023 and 2024?

Thank you.

[serge_lamarre]

@SusanY1 can you help with my previous reply please?

Thank you.

[DaveF1006]

Let's answer these questions one at a time.

1. By all means, file a 2024 return with 8938. 
2. You will need to file amended returns for 2021-2023 which will include the 8938. If you filed with Turbo Tax for those years you can use Turbo Tax to prepare those returns.  i will list the steps below.  if you didn't file with Turbo Tax, then you may prepare the return in the manner you prescribed
3. As far as FBAR, follow the steps as described in this IRS article regarding Delinquent FBAR reporting. File all your FBAR reports, including 2024, using the FinCEN BSA Efiling Link that is listed in the article.

As far as a particular order, there is no prescribed order in doing this but get these filed as soon as possible. I would say to file the 2024 return with 8938 first. Then file FBAR for 2024 as well as for years 2021-2023. File the amended returns last but prepare these as soon as possible and get these mailed in.

Here how how to amend if you used Turbo Tax in yrs 2021-2023.

To amend your return using Turbo Tax Online.

1. Log into Turbo Tax
2. Select Scroll down Your tax returns & documents in your landing page.
3. Select Amend (change) return.  if you used TT Online in the past, years 2021-2023 should appear here.

To amend using the 2021-2023 Desktop Software, go to:

1. Federal Taxes
2. Other Tax Situations>other tax forms
3. Amend a return

Reach out if you have additional questions.

@serge_lamarre 

[serge_lamarre]

@DaveF1006 or any other tax experts.

After reading more about this, I believe it would be better for me to use the 

Streamlined Domestic Offshore Procedures instead than just filling the 1040-X and missing FBARs.

https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-in-the-united-states

I read that doing a quiet disclosure (meaning not going through a special procedure such as 

Streamlined Domestic OIffshore Procedures) may trigger the IRS and have them audit me.

So I am considering the Streamlined Domestic OIffshore Procedures. It looks like an easy procedure to follow. Also, any Canadian Retirement Fund/Pension are not subject to the Title 5% penality which is good for my situation since I had no contributions nor distributions.

Anyone has an opinion on this?

Thank you.

[DaveF1006]

Yes, you are correct. You would use the Streamlined Domestic Offshore Procedures procedure to report your missing FBARS. The amended returns are filed to report 8938's that weren't reported in previous years.

@serge_lamarre 

[ChasinSF]

I am confused by the requirement for a 8938 to be filed. I have used TT for years and never once was I directed to complete this form until this tax year. FBARs yes those I have done. I currently have an RRSP that I have also not contributed to in 30 years since I have lived in the US, and have not yet taken any distributions from. I have also never received an annual report from CIBC outlining capital gains, interest income, dividends etc that form 8938 is asking for. Other questions here on this says you don't need to provide that info, but then TT flags them all as missing. I have found a lot of issues with TT this year, it seems to be making all kinds of errors and no longer is as user friendly in my experience with it this year. A very confusing piece of software to use now! It also still does not handle foreign pension payments easily unlike other programs.

[DaveF1006]

It depends. You may need to file Form 8938 this year because your total foreign accounts (including your RRSP and other accounts) went over the reporting threshold for US residents.

• Single/Married Filing Separately: More than $50,000 on the last day of the year or more than $75,000 at any time.
• Married Filing Jointly: more than $100,000 on the last day of the year or more than $150,000 at any time.

For an RRSP, the income is tax-deferred in the US under the US-Canada treaty. You don't report the internal interest or capital gains on your 1040 until you take a distribution.  The software often "demands" an entry here because it sees a foreign account and assumes this must be taxable income.

To alleviate this assumption, in the Form 8938 section, when it asks for interest/dividends, enter $0. If it asks "Where is this reported on your return?", you can often select "Not reported" or leave the line/form boxes blank. If it still flags an error, some users enter a small note (if the software allows) or just leave it as $0. Since there's no actual distribution, there's no income to report.

Since you haven't contributed in 30 years and haven't taken money out, you don't actually need a specialized tax report from CIBC to file. You do need to keep track of the maximum values of the accounts during the year determined from your monthly statements.  If you have a filing requirement for 8938 based on the parameters given above, you will just need to add this as a custodial account in Part 1 line 5 of the form.  In addition, add this information in Part 1 lines 7 & 8 for information regarding your custodial account. You will need this information when you file your FBAR as well.

[ Edited 02/25/2026 I 8:00am PST]

[ChasinSF]

Thank you Dave. I have not taken any withdrawls yet from this account so you are correct I do not currently have any income to report from the RRSP. My RRSP end of year statement does show the total dividends earned by the RRSP investments. Do I enter this amount on the 8938 ... I am guessing no and not on 1040 3a or 3b either. 

If you have a filing requirement for 8938 based on the parameters given above, you will just need to add this as a custodial account in Part 1 line 5 of the form.  In addition, add this in Part 1 line 6 as part of the total of maximum value of all deposit accounts. You will need this information when you file your FBAR as well.

I am confused by this last sentence in your reply. Why would I report anything on Part 1 Line 6 when I have indicated that my RRSP is a Custodial account? I have no Deposit accounts so there is no maximum value for my deposit accounts to report which is what Line 6 is for so why would I enter any value here?

Finally, my understanding is that form 8938 is a reporting form like a FBAR, is that correct?

Best regards,

Charles

[DaveF1006]

Yes, you are correct. Thank you for pointing out the fact that your RRSP is a custodial account and not a deposit account. Since your RRSP is a Custodial Account, you should leave Lines 5 and 6 blank. You will put "1" on Line 7 and the maximum value of your RRSP on Line 8 on the 8938.

Yes, FBAR and Form 8938 are reporting forms for different agencies. FBAR is a report that is required by the Dept of Treasury while the 8938 is reported to the IRS. 

[silverlight177]

@serge_lamarre 

we are in the same camp with very similar situation, reading your post a year ago and wonder how did you make it through, did you ending using streamlined reporting? 

[serge_lamarre]

Since we have been living in the US, I used the streamlined domestic offshore procedures Read more below.

Streamlined Domestic Offshore Procedures 

I had to submit corrected 1040 for 2024, 2023 and 2022 to add the for 8938. (Last 3 years). This is part of the SDOP submission on paper to the address in the SDOP page above.

Then I had to file the FBAR FinCEN forms for 2024, 2023, 2022, 2021, 2020 and 2019 (Last 6 years). This is filed separately from the SDOP submission because it is filed electronically.

My wife and I still have 3 Canadian retirement accounts (2 RRSP and 1 LIRA). And we still have a Canadian RBC Bank account.

Canadian Retirement Plans are not subject to the 5% penality so we only had to pay for the 5% for our RBC Bank Account which as small.

I did submit all the paperwork on December 30th or 31st I think. It has been more than 3 months and I noticed the the penailty check was deposited by the IRS but no communication to us whatsoever.

Read the SDOP procedure carefully. It is doable. However, I used a specilized firm to verify everything before sending by mail.

I just completed our 2025 taxes and I properly filled out the 8938 as well as the FBAR.

[silverlight177]

This is very helpful information—particularly relevant for expat who worked or lived in Canada.

I have one follow-up question regarding Form 8938 amendments via Form 1040‑X. My understanding was that I would need to amend the prior three years in addition to filing the current year correctly. Using your example timeline as of early 2025, that would imply refiling 2021, 2022, and 2023, while submitting a correct 2024 return.

However, you mentioned that your update covers 2022, 2023, and 2024, which suggests you amended the prior two years and filed the current year correctly. Did I miss anything in my understanding?

[DaveF1006]

No. You didn’t miss anything — both interpretations can be correct depending on which years were actually required to be filed under Form 8938 rules. The confusion comes from mixing two different concepts:

1. How many years you are required to amend, which depends on the statute of limitations and whether Form 8938 was omitted.
2. Which specific years fall into that window, which shifts depending on the current filing year.

 Here is a breakdown, which may help answer your question more clearly.

1. The IRS “six‑year statute” for Form 8938

When Form 8938 is missing, the IRS can examine up to six years back. But that does not automatically mean you must amend all six years. Instead:

1. You must amend every year in that six‑year window in which Form 8938 should have been filed but wasn’t.
2. So the number of amended years depends on:

• When you started having foreign assets above the reporting threshold.
• Which tax years are still open under the six‑year rule.

2. Why your interpretation (2021–2023) is reasonable

If you are filing in early 2025:

1. The six‑year window generally covers 2018–2023. 
2. If you first met the Form 8938 threshold in 2021, then yes:

• You would amend 2021 
• You would amend 2022
• You would amend 2023
• And you would file 2024 correctly

3. Why the earlier example used 2022–2024 instead

In his earlier example, you assumed a different fact pattern:

1. That the taxpayer first crossed the Form 8938 threshold in 2022, not 2021.
2. Under that assumption:

• Amend 2022 
• Amend 2023
• File 2024 correctly
• That’s only two amended years + the current year.

So the difference between your understanding and his example is simply the first year in which Form 8938 was required. If it was required in 2021, that is the year you should start mending your returns to satisfy the six-year statute limitation for Form 8938.

@silverlight177