Moved from Canada to the USA - FBAR Filing

[newestUser]

Hi everyone,

My husband and I became US Green Card holders in October 2023 (but we moved to the US from Canada in Jan 2024, we live in Washington State), and we’re in the process of filing a dual-status 2023 US tax return and completing our FBAR forms - link to FBAR: https://bsaefiling.fincen.treas.gov/NoRegFBARFiler.html

I have a few questions about how to determine the maximum value of our stock accounts. Any advice or official documents/links you can share would be greatly appreciated!

For Accounts Without Daily Statements

For stock accounts like RRSPs or margin accounts, how do you determine the maximum value if the broker doesn’t provide daily statements? For example, with brokers like Questrade, I can only access monthly statements that show the closing balance at month-end. Is it acceptable to use these monthly statements to report the maximum value for FBAR, even though it might be less precise than daily statements? We didn’t track daily values manually, so I’m curious how others handle this situation.

For Accounts With Daily Statements

On the other hand, brokers like Interactive Brokers issue daily statements with the account’s ending value. With over 240 working days in a year, that’s a lot of daily statements to sift through to find the maximum value. Interactive Brokers also provides an account performance analyzer tool that shows a bar chart of daily market values. While this isn’t an official statement, the values do match the daily statement balances. Would it be acceptable to use this tool to determine the maximum value, rather than checking each daily statement individually?

A Few More Questions

1. How should we track the maximum value of our accounts?
2. Since we became U.S. residents in October 2023, should we report the maximum value of an account only from the date we became residents until December 31, 2023?
3. Do accounts like RRSPs and DPSPs require any special reporting, or is completing the FBAR form from the link above sufficient? For example, should I file 3520/3520A for my DPSP?
4. We should also report our bank accounts, right?

Thank you for your help!

[nelsona]

You report all investment and banking accounts (including RRSP and other tax favored account) held in your name, or that you have access to, he files all accounts in his name, and one of you includes the jointly-held accounts on their FBAR.

I would not worry about which value you put. Simply put the highest value at some point during the year (don;t worry about when you arrived in US) and put that value. Its not the value that is critical, it is that you report the accounts.

Of all the forms you file this is the one you need to think about the least.

[newestUser]

[quote=nelsona post_id=530984 time=1728343523 user_id=30]
You report all investment and banking accounts
[/quote]

Do you maybe know if I should file 3520/3520A for my DPSP account?

[nelsona]

Like RRSPs, and RESPs, they are exempt from 3520 trust reporting, but should be included in FBAR.

[ND]

As described at https://www.fincen.gov/reporting-maximum-account-value the maximum value of an account is a reasonable approximation of the greatest value in the account during the calendar year. Most people know off the top their heads if that is $5, $500, $5,000 or $5M. Forget about over-worrying or over-thinking the process. Just put down the number that first comes into your head as the reasonable approximation of the greatest value in the account during the calendar year.

[ND]

RE "Of all the forms you file this is the one you need to think about the least."

FBAR bears criminal consequences and non-compliance can land one in jail. To boot, the penalties are severe.

Of all the forms you file this is the one you need to think about the MOST, for said reasons, incorrectly filing other forms in a manner that isn't with fraudulent intent should only result in higher tax and penalty.

Of all the forms you file, FBAR should require the least amount of focus and attention to accurately complete it in full satisfaction of FinCen requirements. Its actual reporting is simple and easy in nature.

[nelsona]

Like I said.