# Historical Average Exchange Rates: How can I find them?



## Rodiy2k17 (Nov 27, 2016)

Hello
Does anyone know where I can find annual exchange rates (specifically USD to CAD) that would be acceptable by the IRS from 1994 through 2006? The IRS website lists the last 10 years and if you follow their link to the newly revised US Treasury Dept site (fiscaldata.treasury.gov), you can also only get 10 years. For the three independent services they list (Oanda, XE and x-rates), only one has historical data that old and requires premium membership

As an alternative, does anyone have a suggestion on what to use in the absence of available rates? 

The purpose is for determination of cost basis on a distribution from a Canadian Registered Retirement Savings Plan (RRSP). Lifetime contributions are not taxable for US purposes but must be converted. Due to excessive entries over 30 years, I assume the annual exchange rate for each year would be acceptable. We live in Canada and file joint returns in the US as well as Canadian returns. My wife has dual citizenship and is therefore a "U.S. person" for tax purposes.

Thank You


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## Moulard (Feb 3, 2017)

Its not annual but US Treasury at least has quarterly









Treasury Reporting Rates of Exchange | U.S. Treasury Fiscal Data


Exchange rate information for foreign currencies and their U.S. dollar equivalents, updated quarterly.




fiscaldata.treasury.gov


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## Rodiy2k17 (Nov 27, 2016)

Moulard said:


> Its not annual but US Treasury at least has quarterly
> 
> 
> 
> ...


Hi
Thanks for the reply. I already tried that link. It goes back as far as 10 years. If you click "all" you get a 3500 line downloadable spreadsheet that starts with 2011


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## Nononymous (Jul 12, 2011)

Any particular reason why your wife bothers filing, and in particular why you are dragged into a joint return despite not being a US citizen? The vast majority of dual citizens in Canada do not bother. If it's any consolation, RRSP accounts are not subject to FATCA reporting, so the only way the IRS knows anything about them is if you declare it yourself.


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## Moulard (Feb 3, 2017)

Sorry, I saw the ALL link and assumed that givent there was a 10 year button and an ALL there was significantly more than 10 years behind it


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## Rodiy2k17 (Nov 27, 2016)

Nononymous said:


> Any particular reason why your wife bothers filing, and in particular why you are dragged into a joint return despite not being a US citizen? The vast majority of dual citizens in Canada do not bother. If it's any consolation, RRSP accounts are not subject to FATCA reporting, so the only way the IRS knows anything about them is if you declare it yourself.


We are both US citizens but I am not a Canadian citizen. All US citizens are responsible for filing and reporting all worldwide income. I was raised to follow laws and that's why we file despite today's sad world where so many people "don't bother". A Distribution from a foreign retirement plan is income and RRSP's have special considerations regarding US taxation.

You don't know anything about our situation which renders your response incorrect but to answer your question, we have been married 20 years which means we used to file the form 8891 which exempted her RRSP from US taxation as long as funds remain in the plan. That requirement is now obsolete but the IRS is fully aware of my wife's RRSP. 

You are also incorrect regarding FATCA. When we moved back to Canada from overseas last year, the brokerage firm holding the RRSP was required to open a new account due to a residency change from foreign to Canadian. All US persons holding an RRSP are required to file a W9 with the RRSP holder when the account is opened. The reason for that is is because Canadian financial institutions are responsible for sending substitute 1099R forms on any distributions taken by US persons as well as any other substitute tax forms on worldwide income that may be subject to US taxation. RRSP distributions are considered annuity payments for US tax purposes which is as form of passive income or part "c" on the Form 1116 (foreign tax credits)

Finally, we have passive income in the USA and it makes no financial sense to file as "married filing separate" in the USA.


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## Nononymous (Jul 12, 2011)

It's not really "today's sad world" that's the problem: tax compliance by dual citizens was even lower before FATCA came along and raised awareness. Rampant non-filing has less to do with deliberate disobedience than being simply unaware, plus the fact that the IRS has very limited reach outside the country. But I digress. My concern is primarily for "Accidental Americans" who are lured into filing needlessly (or entangling their non-US spouses) not single-citizenship expats such as yourself, particularly those with US financial entanglements already.

Regarding RRSPs, they are quite clearly *not* subject to FATCA reporting. I refer you to section IV of the US-Canada Intergovernmental Agreement (see page 45). You'll note that TFSAs and many other registered account types are also excluded. Financial institutions may choose to use a W-9 (or W-8BEN) form to determine their customers' US person status, but most now use their own forms, often combining FATCA and CRS questions. Enforcement is extremely lax in Canada. When opening an account you are only required to produce a drivers license as identification, which does not show place of birth, so it is extremely easy for Canadians born in the US to conceal their citizenship and avoid FATCA completely.

I am not aware that Canadian financial institutions are responsible for issuing "substitute 1099R forms on any distributions taken by US persons as well as any other substitute tax forms on worldwide income that may be subject to US taxation." This may be something that your brokerage firm does, but in many years of following this issue as part of the Canadian movement opposed to FATCA, I have never heard of Canadian banks routinely reporting such information to the IRS.


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## Rodiy2k17 (Nov 27, 2016)

Moulard said:


> Sorry, I saw the ALL link and assumed that givent there was a 10 year button and an ALL there was significantly more than 10 years behind it


Yes I thought the same thing


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## Rodiy2k17 (Nov 27, 2016)

Nononymous said:


> It's not really "today's sad world" that's the problem: tax compliance by dual citizens was even lower before FATCA came along and raised awareness. Rampant non-filing has less to do with deliberate disobedience than being simply unaware, plus the fact that the IRS has very limited reach outside the country. But I digress. My concern is primarily for "Accidental Americans" who are lured into filing needlessly (or entangling their non-US spouses) not single-citizenship expats such as yourself, particularly those with US financial entanglements already.
> 
> Regarding RRSPs, they are quite clearly *not* subject to FATCA reporting. I refer you to section IV of the US-Canada Intergovernmental Agreement (see page 45). You'll note that TFSAs and many other registered account types are also excluded. Financial institutions may choose to use a W-9 (or W-8BEN) form to determine their customers' US person status, but most now use their own forms, often combining FATCA and CRS questions. Enforcement is extremely lax in Canada. When opening an account you are only required to produce a drivers license as identification, which does not show place of birth, so it is extremely easy for Canadians born in the US to conceal their citizenship and avoid FATCA completely.
> 
> I am not aware that Canadian financial institutions are responsible for issuing "substitute 1099R forms on any distributions taken by US persons as well as any other substitute tax forms on worldwide income that may be subject to US taxation." This may be something that your brokerage firm does, but in many years of following this issue as part of the Canadian movement opposed to FATCA, I have never heard of Canadian banks routinely reporting such information to the IRS.


I‘m perfectly aware that nobody follows any rules any more. I once worked for a financial institution in Canada that knowingly violated US tax reporting rules. I know this because I was responsible for US tax issues for Canadians with US securities. That’s not really the point.

My tax professional in the USA and a phone conversation with the IRS international tax services confirms that a distribution from an RRSP is taxable in the US as passive income to the extent that the distribution exceeds the cost basis which is all lifetime contributions. FATCA reporting has nothing to do with my question. Neither of us are subject to FATCA reporting as it relates to our tax returns because our assets fall below reporting thresholds. However, if you’re trying to tell me that we should simply withdraw $100K CAD and not report it appropriately on our US tax return because nobody bothers or cares, you’d be condoning breaking the law. The tax is refundable by using Form 1116 which protects from double taxation.


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## Nononymous (Jul 12, 2011)

I'd suggest that there is probably more rule-following than rule-breaking nowadays because FATCA has raised awareness of the rules' very existence.

I did not claim that an RRSP distribution is not considered taxable by the US. I simply said that RRSPs are not reported at all under FATCA, so that only way the US authorities would know that a Canadian resident has an RRSP is if this person reports it on their FBAR form and tax return. Whether one should or should not report it appropriately is a separate question. It's obviously possible to ignore these obligations because the vast majority of dual citizens in Canada do not file US tax returns at all, and suffer no harm for their failure to do so.


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## Rodiy2k17 (Nov 27, 2016)

That may be. All of my life savings, assets and ties are in the USA so while I live in Canada, I choose to follow the taxation rules as they exist even though I don’t like them. And again, American citizens living overseas and not reporting worldwide income are all breaking the law unless they have less than the threshold for tax filing which is Less than than the standard deduction in income.


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## Nononymous (Jul 12, 2011)

Indeed. Millions of persons around the world with US citizenship by virtue of birth or parentage are breaking US law, wittingly or unwittingly. Oh well. Not much the IRS can do about it, nor do they try. 

Imagine what it would have cost US taxpayers if these scofflaw millions all began filing last year and received their $3200 in stimulus benefits!

Though this most certainly does not apply to your situation, as a general rule Accidental Americans with no US financial ties are best served by staying out of the US tax system, and avoiding FATCA by concealing US citizenship if possible. Those who face banking restrictions due to their US birthplace may have no other option but to renounce - for which tax compliance is not required.


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## Rodiy2k17 (Nov 27, 2016)

I have no issue with your comments on those stuck with taxation due to being accidental Americans.

Unfortunately, it doesn’t resolve my problem which is why I actually posted but thanks for the intelligent discussion. We received all three stimulus payments while living in Thailand and Canada so I don’t mind filing returns which have zero liability anyway. we have no choice but to file in Canada but receive benefits like GST credits which are not designed for people with seven figure asset figures but the rules go by income and we have almost none of that. Cheers


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