“I am a Canadian citizen moving to New York soon to work as an RN on a TN visa. How will my 2026 tax residency work, and what are my US filing obligations for my Canadian TFSA, FHSA, RRSP, investments, and bank accounts once I start working in the US?”
If you first arrive late in 2026 with little or no earlier U.S. presence, you will ordinarily miss that year’s 183-day weighted test; the first-year choice is a separate possibility, not an automatic consequence of working. You can keep track of the issue with a day calendar and an account inventory rather than assuming every Canadian account requires every U.S. form.
Your federal filing path turns first on your U.S. day count, with a possible election if you arrive too late to meet the 2026 test.
If you have at least 31 U.S. days in 2026 and at least 183 weighted days across 2024–2026, you generally become a U.S. tax resident from your first U.S. presence in 2026. If you began the year a nonresident and remain resident at year-end, file a Form 1040 with a Form 1040-NR statement; report worldwide income for the resident period and test foreign-account disclosures. [IRS day-count test](https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test); [IRS starting dates](https://www.irs.gov/individuals/international-taxpayers/residency-starting-and-ending-dates); [IRS dual-status filing](https://www.irs.gov/individuals/international-taxpayers/taxation-of-dual-status-individuals).
If you were not a U.S. resident in 2025, miss the 2026 test, have at least 31 consecutive U.S. days in 2026 and meet the first-year presence condition for the rest of 2026, you can make the if you meet substantial presence in 2027. This produces a 2026 resident starting period and a dual-status return; attach the election statement to Form 1040. You cannot complete the required 31-day block by December 31 if your first possible arrival is after December 1. [IRS first-year choice](https://www.irs.gov/individuals/international-taxpayers/tax-residency-status-first-year-choice).
If you neither meet the 2026 day-count test nor make a valid first-year choice, file Form 1040-NR for your taxable U.S. nursing wages. Your TN employment alone does not turn Canadian accounts into U.S.-resident income for 2026 or, absent another qualifying status, make you a U.S. person for resident-based FBAR/Form 8938 reporting; reassess in 2027. [IRS day-count test](https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test); [Form 1040-NR instructions](https://www.irs.gov/instructions/i1040nr); [IRS FBAR](https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar); [Form 8938 instructions](https://www.irs.gov/instructions/i8938).
Canada decides its residency separately; if both countries treat you as resident, the treaty’s may change your U.S. income-tax return, but does not automatically cancel other reporting. [Treaty, Article IV](https://www.canada.ca/en/department-finance/programs/tax-policy/tax-treaties/country/united-states-america-convention-consolidated-1980-1983-1984-1995-1997-2007.html); [26 CFR 301.7701(b)-7](https://www.ecfr.gov/current/title-26/section-301.7701(b)-7).
Work through residency first, then classify the accounts and file only the returns your facts trigger.
Before choosing a 2026 return
Count your days and establish your move dates
Use the IRS [substantial-presence formula](https://www.irs.gov/individuals/international-taxpayers/substantial-presence-test): 31 actual U.S. days in 2026 and 183 weighted days using all 2026 days, one-third of 2025 days and one-sixth of 2024 days. Separately apply [CRA’s departure-residency rules](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/leaving-canada-emigrants.html) to the date you leave, your family and the residence you retain; record when New York becomes your home under [New York’s residency rules](https://www.tax.ny.gov/pit/file/nonresident-faqs.htm).
Requirements
Before reporting accounts
Inventory and classify every Canadian account
Separate the accounts’ income from information reporting. If you are a U.S. person for FBAR purposes, aggregate foreign financial accounts against the $10,000-at-any-time threshold and file FinCEN Form 114 at [BSA E-Filing](https://bsaefiling.fincen.gov/) if required; its 2026 deadline is April 15, 2027, with an automatic extension to October 15, 2027. Separately, apply [Form 8938 instructions](https://www.irs.gov/instructions/i8938): for an unmarried person living in New York, specified foreign financial assets must exceed $50,000 at year-end or $75,000 at any time; for spouses filing jointly, the figures are $100,000 and $150,000. Form 8938 attaches to the income-tax return if required. Test any foreign-trust ownership or transaction under the [IRS trust rules](https://www.irs.gov/businesses/international-businesses/foreign-trust-reporting-requirements-and-tax-consequences), and any applicable foreign-fund holding under the [Form 8621 instructions](https://www.irs.gov/instructions/i8621); neither form follows from the account’s Canadian label alone.
Requirements
If your arrangement is a reportable foreign trust
Resolve any foreign-trust returns before their deadlines
If you are treated as the U.S. owner of a reportable foreign trust with a December 31 trust year, the trust’s [Form 3520-A](https://www.irs.gov/instructions/i3520a) is ordinarily due March 15, 2027; the owner may need a substitute filing if the trust does not file. Your applicable [Form 3520](https://www.irs.gov/instructions/i3520) is generally due April 15, 2027. The IRS expressly relieves RRSPs/RRIFs from these forms, but do not extend that exception to a TFSA or FHSA without establishing its own treatment. [IRS trust guidance](https://www.irs.gov/businesses/international-businesses/foreign-trust-reporting-requirements-and-tax-consequences).
Requirements
Generally by April 15, 2027
File the U.S. federal and New York returns
For 2026 U.S. wages, file [Form 1040-NR](https://www.irs.gov/instructions/i1040nr) if you remain a federal nonresident; if you become a resident during 2026 and remain one at year-end, file [Form 1040 marked Dual-Status Return with a Form 1040-NR statement](https://www.irs.gov/individuals/international-taxpayers/taxation-of-dual-status-individuals). If making a valid [first-year choice](https://www.irs.gov/individuals/international-taxpayers/tax-residency-status-first-year-choice), attach its statement and meet the 2027 presence test; use [Form 4868](https://www.irs.gov/pub/irs-pdf/f4868.pdf) by April 15, 2027 if you need filing time while waiting, without treating the extension as more time to pay. If you have a New York filing obligation as a part-year resident, file [Form IT-203](https://www.tax.ny.gov/pit/file/part_year_residents.htm) by April 15, 2027. New York City resident tax applies only if your home is in the city. Assess a [foreign tax credit, generally Form 1116](https://www.irs.gov/individuals/international-taxpayers/foreign-tax-credit), for eligible tax paid on income also taxed by the United States.
Requirements
Ordinarily by April 30, 2027
Complete your Canadian 2026 return
If you became a Canadian nonresident in 2026, enter the departure date on your Canadian return, report income for the appropriate resident and nonresident periods, and address any deemed dispositions of investments with [Form T1243](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html). Assess [Form T1161](https://www.canada.ca/en/revenue-agency/services/tax/international-non-residents/individuals-leaving-entering-canada-non-residents/dispositions-property.html) if the fair market value of property owned on departure exceeds CAD $25,000, applying CRA’s exclusions. The ordinary individual filing date is [April 30 following the tax year](https://laws-lois.justice.gc.ca/eng/acts/i-3.3/section-150.html); the statutory June 15 exception can apply to someone carrying on a business or their spouse. If you remained a Canadian resident, do not claim a departure date merely because you started a TN job.
Requirements
You are not the first to go through this. Here is how it went for others who asked the same thing.
u/Effective_Juicer176r/USExpatTaxesAug 9, 2026
u/Nalesr/tnvisaAug 15, 2026
This answer draws on IRS and FinCEN filing rules, Canada Revenue Agency guidance, the Canada–U.S. tax treaty, federal regulations and New York tax rules.
IRC 7701(b); IRS Substantial Presence Test
The 2026 test counts days across three calendar years rather than relying on TN status.
Substantial Presence Test
183 days during the 3-year period that includes the current year and the 2 years immediately before that, counting:
IRS Residency Starting and Ending Dates
A qualifying resident year usually starts on the first U.S. presence day, which need not be the job-start date.
Residency starting date under substantial presence test
If you meet the substantial presence test for a calendar year, your residency starting date is generally the first day you are present in the United States during that calendar year.
IRS First-Year Choice
A qualifying first-year election is made with a statement attached to the resident return.
First-Year Choice
You must attach a statement to Form 1040 to make the first-year choice.
IRS Taxation of Dual-Status Individuals
The resident portion of a dual-status year brings worldwide income into the U.S. return.
Income subject to tax
For the part of the year you are a U.S. resident, you are taxed on income from all sources.
IRS Taxation of Resident Aliens
A Canadian account’s Canadian tax preference does not by itself exclude its income from a U.S. resident return.
Taxation of resident aliens
If you are a U.S. resident, you must report all interest, dividends, wages, or other compensation for services, income from rental property or royalties, and other types of income on your U.S. tax return. You must report these amounts whether they are earned within or outside the United States.
CRA Leaving Canada (Emigrants)
Canadian residence is a separate factual and potentially treaty-based question.
Your residency status
However, if you are also considered to be a resident of another country with which Canada has a tax treaty, you may be considered a deemed non-resident of Canada.
Canada–U.S. Tax Convention Art. IV(2)
The treaty first examines available permanent homes and then closer personal and economic connections.
Article IV(2)(a)
(a) he shall be deemed to be a resident of the Contracting State in which he has a permanent home available to him; if he has a permanent home available to him in both States or in neither State, he shall be deemed to be a resident of the Contracting State with which his personal and economic relations are closer (centre of vital interests);
26 CFR 301.7701(b)-7(a)(3)
An income-tax treaty residence claim is not an automatic escape from every U.S. reporting rule.
(a)(3)
Generally, for purposes of the Internal Revenue Code other than the computation of the individual's United States income tax liability, the individual shall be treated as a United States resident.
CRA How Non-Residency Affects Your TFSA
Emigration does not itself force closure of an existing TFSA.
If you become a non-resident
If you become a non-resident, you are allowed to keep your existing TFSA.
CRA How Non-Residency Affects Your TFSA
Canadian nonresident TFSA contributions can trigger a monthly Canadian tax even when room otherwise exists.
Non-resident contributions
Any non-resident contribution you make, except for a qualifying transfer or an exempt contribution, is subject to a **1% tax** for each month the contribution remains in the account.
CRA FHSA Withdrawals and Transfers
Canadian residency is an express condition of a qualifying FHSA home withdrawal.
Qualifying withdrawals
You must be a resident of Canada from the time that you make your first qualifying withdrawal from one of your FHSAs until the earlier of the acquisition of the qualifying home, or the date of your death.
Canada–U.S. Tax Convention Art. XVIII(7)
The treaty provides a particular deferral mechanism for eligible Canadian retirement arrangements, not a general TFSA or FHSA exclusion.
Article XVIII(7)
A natural person who is a citizen or resident of a Contracting State and a beneficiary of a trust, company, organization or other arrangement that is a resident of the other Contracting State, generally exempt from income taxation in that other State and operated exclusively to provide pension or employee benefits may elect to defer taxation in the first-mentioned State, subject to rules established by the competent authority of that State, with respect to any income accrued in the plan but not distributed by the plan, until such time as and to the extent that a distribution is made from the plan or any plan substituted therefor.
IRS Foreign Trust Reporting Requirements
The IRS expressly exempts RRSPs and RRIFs from these two foreign-trust information returns.
Canadian retirement plans
Forms 3520 and 3520-A are not required to be filed for Canadian registered retirement savings plans (RRSPs) and Canadian registered retirement income funds (RRIFs).
Revenue Procedure 2014-55
The RRSP procedure preserves other applicable foreign-asset and foreign-account disclosure duties.
Section 4
This revenue procedure does not, however, affect any reporting obligations that a beneficiary or annuitant of a Canadian retirement plan may have under section 6038D or under any other provision of U.S. law, including the requirement to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), imposed by 31 U.S.C. § 5314 and the regulations thereunder.
Revenue Procedure 2020-17
The special foreign-trust reporting relief is defined by specified purposes; it is not blanket relief for every Canadian registered savings account.
Section 5.03
For purposes of this revenue procedure, a tax-favored foreign non-retirement savings trust means a foreign trust for U.S. tax purposes that is created, organized, or otherwise established under the laws of a foreign jurisdiction (the trust’s jurisdiction) as a trust, plan, fund, scheme, or other arrangement (collectively, a trust) to operate exclusively or almost exclusively to provide, or to earn income for the provision of, medical, disability, or educational benefits, and that meets the following requirements established by the laws of the trust’s jurisdiction.
FinCEN Form 114; IRS FBAR Guidance
FBAR uses a combined foreign-account threshold, not an income threshold or a separate threshold per account.
Who must file
the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported.
Instructions for Form 8938
For an unmarried U.S. resident living in New York, Form 8938 has higher, separate asset thresholds than FBAR.
Reporting Thresholds Applying to Specified Individuals Living in the United States
If you are not married, you satisfy the reporting threshold only if the total value of your specified foreign financial assets is more than $50,000 on the last day of the tax year or more than $75,000 at any time during the tax year.
New York Tax Law § 651(a)
New York’s ordinary calendar-year income-tax filing deadline is April 15 of the following year.
Tax Law § 651(a)
On or before the fifteenth day of the fourth month following the close of the taxable year, an income tax return under this article shall be made and filed by or for:
These are the official rules in the cited sources as available for this answer; rules and form instructions can change.
This is general information about official tax processes, not legal or tax advice, and SettleKit is not a law firm.
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