Foreign Asset Reporting Deadlines Compared: FBAR, Form 8938, T1135 and India Schedule FA

Foreign asset reporting deadlines in the United States, Canada and India are separate obligations with different thresholds, filing channels and penalties, and a family with accounts in two or three countries often owes more than one report on the same bank balance. The U.S. FBAR and Form 8938, Canada's Form T1135 and India's Schedule FA are each triggered by residence, not by whether the asset produced taxable income. This page lines the four up so you can see which apply and when, for the 2026 reporting year.

How do foreign asset reporting deadlines compare?

What are the U.S. rules?

FBAR. A U.S. person with a financial interest in, or signature authority over, foreign financial accounts must file if the aggregate value exceeded $10,000 at any time in the calendar year. The report is e-filed through FinCEN's BSA E-Filing system, not attached to your return, and includes each account's maximum value during the year. You keep account records for five years from the due date. The April 15 date has an automatic extension to October 15 with no request. Walk through it in the FBAR guide.

Form 8938. Attached to Form 1040 and due with it. The thresholds in the IRS instructions are:

The penalty for failing to file is $10,000, with up to $50,000 more if the failure continues after the IRS sends notice. See Form 8938 step by step.

What are the Canadian rules?

Form T1135 must be filed by Canadian resident individuals, corporations and certain trusts that owned specified foreign property costing more than CAD 100,000 at any time in the year, and by certain partnerships. It is due on the same date as the income tax return. Individuals file by April 30; people who carried on a business file by June 15 but still pay by April 30. If total cost stayed under CAD 250,000 throughout the year you can use the simplified checkbox method (Part A); at CAD 250,000 or more you use the detailed method (Part B). Personal-use property and property used exclusively in an active business are excluded. The late filing penalty is $25 per day for up to 100 days, with a $100 minimum and $2,500 maximum, and knowing or grossly negligent failures attract $500 per month for up to 24 months (maximum $12,000) and then 5% of the property's cost. See T1135 foreign property reporting.

What are the Indian rules?

Schedule FA is the foreign assets schedule in the Indian income tax return, covering foreign bank accounts, equity and debt interests, immovable property, signing authority and similar items. It applies to a resident other than a person who is "not ordinarily resident"; non-residents and RNORs generally have no Schedule FA duty. The Black Money Act penalty for omitting a foreign asset from the return is Rs 10 lakh, with an exemption where the aggregate value of non-immovable assets is Rs 20 lakh or less, and willful failure is punishable with rigorous imprisonment of six months to seven years and a fine. The long-standing return date for individuals without an audit is July 31, and your Chartered Accountant confirms the date that applies under the Income-tax Act, 2025 for tax year 2026-27; for assessment year 2026-27, CBDT Circular 07/2026 extended the return date for tax-audit cases from October 31 to November 21, 2026. Read Schedule FA and the Black Money Act.

India's Foreign Assets of Small Taxpayers Disclosure Scheme, 2026 (rules effective August 16, 2026) lets eligible taxpayers declare foreign assets by December 31, 2026, valued as of March 31, 2026. The rules' illustrations show tax of 30% plus an equal penalty for undisclosed assets and income up to Rs 1 crore in total, and a Rs 1 lakh fee for assets up to Rs 5 crore acquired from income already taxed or earned while non-resident but not reported in the schedule. Eligibility sits in the Finance Act, 2026, so your Chartered Accountant decides whether it fits.

How do you coordinate reports across the three countries?

1. List every account and asset by owner, country, institution, type and opening date.
2. Record three numbers for each: maximum value for the FBAR and Form 8938, cost for the T1135, and peak and closing balances for Schedule FA.
3. Test each rule separately. A U.S. citizen resident in Canada may file an FBAR, Form 8938 and a T1135; an Indian resident with U.S. brokerage accounts files Schedule FA but may have no U.S. duty at all.
4. Calendar the four channels: FinCEN, the IRS return, the CRA return and the Indian return.
5. Use one set of exchange rates and sources per report and keep the workpapers; reconcile differences.
6. Fix late filings through the right door: the IRS streamlined and delinquent procedures, the CRA Voluntary Disclosures Program, or the Indian scheme above. See IRS foreign reporting penalties.

Worked example

Sunita is a U.S. green card holder in Aurora with a joint Indian savings account of $40,000 and a Toronto RRSP she keeps from earlier work. She files jointly. FBAR: aggregate foreign accounts exceed $10,000, so she files by April 15, 2027, extended to October 15, 2027. Form 8938: because she is a U.S. resident filing jointly, her thresholds are $100,000 at year-end or $150,000 at any time, so she tallies the RRSP, Indian accounts and any foreign investment accounts before deciding. T1135: not applicable, because she is not a Canadian resident. Schedule FA: not applicable unless she becomes an Indian tax resident. If she moved to Mississauga, the picture would change: T1135 would apply above CAD 100,000, and the U.S. reports would continue.

Mistakes to avoid

• Assuming the FBAR is filed with the return; it is not.
• Using market value for the T1135, which tests cost, or cost for the FBAR, which uses maximum value.
• Treating an automatic FBAR extension as an extension for Form 8938 or T1135; those follow the return.
• Ignoring joint accounts, signature authority and accounts opened years ago and long forgotten.
• Assuming that no tax due means no report due.

How we can help

We are a CPA firm in the Aurora area and prepare FBARs, Forms 8938 and related U.S. international forms. For Canadian and Indian reports we coordinate with your Canadian CPA and Indian Chartered Accountant, who file under their own law, so the account lists and values agree across the filings. See foreign account and asset reporting and the U.S. federal tax calendar.

Frequently asked questions

General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.