FBAR vs T1135 vs Schedule FA: Foreign Account and Asset Reporting Compared

FBAR vs T1135 vs Schedule FA is the comparison that families with ties to India, Canada and the United States ask us for most often. All three countries want to know about your bank accounts and investments abroad, but each uses a different form, a different trigger and a different measure of value, so having one report does not satisfy another. This guide, which supplements our T1135 guide and Schedule FA guide, puts the four main reports side by side: the U.S. FBAR and Form 8938, Canada's Form T1135, and Schedule FA of the Indian income tax return.

FBAR vs T1135 vs Schedule FA: how do the reports compare?

Who needs to file which?

• Indian-born U.S. citizen or green card holder in Aurora: FBAR and, above the thresholds, Form 8938 for Indian, Canadian or other accounts. Schedule FA only if you are an Indian resident.
• H-1B holder who is a U.S. resident alien: the same U.S. reports. The Indian Schedule FA applies only if you are resident in India for the Indian year.
• Canadian resident with Indian property or accounts: T1135 if cost passes CAD 100,000; the FBAR only if you are also a U.S. person.
• Returned NRI who is resident but not RNOR in India: Schedule FA for U.S. accounts and assets. If you are still a U.S. citizen or green card holder, FBAR and Form 8938 too.
• Person tied to all three: potentially all four reports, each with its own measurement date.

Details that trip people up

Measuring value. FBAR uses the maximum account value during the year in dollars. Form 8938 uses year-end and maximum value. The T1135 threshold is based on cost, not market value, and counts even if you sold the property before year-end. Schedule FA uses peak balance and closing balance, converted into rupees at the State Bank of India telegraphic transfer buying rate on the relevant date.

Periods. Schedule FA looks at the calendar year ending December 31. For the return for assessment year 2025-26, the department's guide says that period is January 1 to December 31, 2024, so for assessment year 2026-27 the same pattern points to calendar year 2025. The Chartered Accountant confirms the periods for the new Income-tax Act, 2025 return forms.

New residents. CRA's Q&A says a person does not file a T1135 for the year they first become a Canadian resident.

Retirement plans. An RRSP is not reported on the T1135, but it can be an FBAR and Form 8938 item for a U.S. person. Foreign pension plan interests are reportable on Form 8938. See retirement planning across three countries.

Reassessment periods. Missing reports keep the door open. In the U.S., a failure to file Form 8938 can leave the statute open until 3 years after the form is filed, and omitting more than $5,000 of income from foreign financial assets extends the period to 6 years. In Canada, CRA extends the reassessment period by 3 years where income from specified foreign property was unreported and the T1135 was late or wrong. See audit and assessment timelines by country.

How to build one master schedule

1. Open a spreadsheet with one row per account or asset: country, institution, holder names, type, opening date, currency and account number.
2. Add columns for each measure: maximum balance in local currency, year-end balance, cost, and the dollar, Canadian dollar or rupee equivalent at the right date and rate.
3. Mark each row for each report that might apply: FBAR, Form 8938, T1135, Schedule FA.
4. Reconcile with the three tax returns and with annual statements and Forms 26AS or AIS in India.
5. Hand the same file to your U.S. CPA, your Canadian CPA and your Indian Chartered Accountant.

Worked example

Vikram, a green card holder in Aurora, has an Indian NRO account ($30,000), Indian mutual funds ($40,000), and a Toronto RRSP (CAD 60,000) from an earlier job. His FBAR is required because the accounts together exceed $10,000. His Form 8938 is required because the total passes $50,000 at year-end. He does not file a T1135, because he is not a Canadian resident, and he does not complete Schedule FA, because he is not resident in India. His sister Meera in Mississauga holds an Indian bank account and a rented Pune flat that cost the equivalent of CAD 200,000. Her T1135 is required because cost exceeds CAD 100,000, and she files it with her T1. All amounts are hypothetical.

Mistakes to avoid

• Filing an FBAR but not Form 8938, or the reverse.
• Reporting market value on a T1135 where cost is the measure.
• Using ITR-1 for an Indian return when foreign assets exist; the department's guide says ITR-1 and ITR-4 do not include Schedule FA.
• Forgetting assets where you only hold signing authority.
• Forgetting that India, Canada and the U.S. exchange account data with each other's tax authorities through FATCA and CRS.

How we can help

We prepare the U.S. reports, FBAR and Form 8938, for clients in Aurora and the Fox Valley, and we coordinate with your Canadian CPA for the T1135 and your Indian Chartered Accountant for Schedule FA, so one master schedule feeds all three filings. See our foreign account and asset reporting service and our FBAR guide. We do not file Canadian or Indian forms.

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.