US Citizens in Canada Tax Calculator
Rough estimator for the combined Canadian + US tax burden of a US-citizen Canadian-resident. Applies Foreign Tax Credit to offset US tax on Canadian-source income.
Your dual-filing estimator
$15,497 total combined tax (CAD)
Canadian $15,497 + residual US $0 after FTC.
| Canadian tax (primary) | $15,497 |
| US gross tax (estimate) | $6,657 |
| Foreign Tax Credit applied | −$6,657 |
| Residual US tax owed | $0 |
Estimate only. Does not model AMT, NIIT, state tax, or Form 8833 RRSP treaty election. Cross-border accountant recommended.
How dual filing works
Canada taxes you on worldwide income because you are resident here. The US taxes you on worldwide income because you are a US citizen — the only major country that uses citizenship-based taxation (the other is Eritrea). The Canada-US Tax Treaty allocates primary taxing rights to Canada for most income earned in Canada, and the FTC mechanism on Form 1116 prevents double taxation by crediting Canadian tax against US tax. At most income levels, Canadian rates are higher than US rates, so the FTC fully offsets US tax and you owe nothing additional to the IRS — but you must still file the 1040 every year.
TFSAs and US tax
The TFSA is not recognized by the US tax code. All income earned inside a TFSA (interest, dividends, capital gains) is fully taxable each year on the US 1040 as it accrues, regardless of whether you make a withdrawal. Many US-citizen Canadians intentionally underfund their TFSAs for this reason, preferring RRSPs (which are treaty-protected) for tax-deferred saving.
RRSP treaty protection
Article XVIII of the Canada-US Tax Treaty defers US tax on RRSP/RRIF earnings until withdrawal. Since 2014, no annual Form 8891 election is required — the deferral is automatic. On withdrawal, Canada withholds non-resident tax (25% by default, 15% under the treaty) and the US picks up the gross amount minus a partial basis recovery, with FTC for the Canadian withholding.
FBAR and Form 8938
FBAR (FinCEN 114) and Form 8938 (FATCA) are separate reporting obligations with different thresholds. FBAR triggers at USD 10,000 aggregate at any time during the year, across all non-US accounts including TFSA, RRSP, RESP, FHSA, brokerage, and even employer pension accruals. Form 8938 triggers at higher thresholds (single resident abroad: USD 200,000 at year-end / 300,000 at any time). Penalties for non-filing are severe — surface the obligation in your year-1 cross-border accountant engagement, not at the IRS audit stage.
Related decisions
If you are planning to return to the US or move to a third country, see the Departure Tax Calculator for Canadian-side consequences. If you spend significant time in the US even as a Canadian resident, see the Snowbird Substantial Presence Calculator for US tax-residency tests.
Frequently asked questions
Do US citizens in Canada pay tax in both countries?
Yes. The US is one of only a handful of countries that taxes citizens on worldwide income regardless of where they live. US citizens resident in Canada file both a Canadian T1 (as the primary jurisdiction) and a US 1040 (as US citizens). The Foreign Tax Credit (Form 1116) typically eliminates US tax on Canadian-source income because Canadian marginal rates are higher than US rates at most income levels — but the dual filing obligation remains.
Is my TFSA US-tax-deferred?
No. TFSAs are not recognized by the US tax code as deferred-tax vehicles, so all TFSA income (interest, dividends, capital gains) is fully taxable each year on your US return as it accrues — even if you don't withdraw. Most US-citizen Canadians underuse the TFSA for this reason. RRSPs, by contrast, are protected by the Canada-US tax treaty and the deferral is automatic (no Form 8833 election required since 2014).
What is FBAR and do I need to file it?
FBAR (FinCEN Form 114) is required if the aggregate maximum value of all your non-US financial accounts (chequing, savings, brokerage, TFSA, RRSP, RESP, FHSA, employer benefits) exceeds USD 10,000 at any point in the year. FBAR is filed separately from your 1040, due April 15 with automatic extension to October 15. Penalties for non-filing are severe — even non-willful penalties start at USD 10,000 per account per year. Form 8938 (FATCA) has higher thresholds and is filed with the 1040.