Reporting RRSP with Form 8938 and FBAR

Forum|Forum|1 year ago
February 18, 2025
2 replies
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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.

Not A Product Question

SusanY1

Level 15

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

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serge_lamarreAuthor

Level 2

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_lamarreAuthor

Level 2

@SusanY1 can you help with my previous reply please?

Thank you.

silverlight177

Level 2

@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_lamarreAuthor

Level 2

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

Level 2

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?