Canadian Pension Account

Under the treaty, the RRSP is considered a pension. As such, one does not need to answer Yes to the 1040 question on cryptocurrency. As transactions inside a pension are not reported I see no reason why anything would show up on a 1040 until such time there is a distribution from the RRSP. The treaty says the US resident reports the taxable amount based on what would have been taxable if the person was a Canadian resident. Canada reserves the right to tax the distribution (this would trigger an FTC on the US return) but at a rate no higher than 15%.

So effectively, only the FBAR and the 8938 would have to be filed to disclose the foreign account.

Thanks Alan. That was my conclusion too. But while I deal with a lot of tax issues, I don't do returns, so I wanted the perspective of someone who is close to this issue.