FBAR (FinCEN Form 114) — Foreign Bank Account Reporting

U.S. persons with foreign bank or financial accounts exceeding $10,000 must file the FBAR each year. Penalties for non-compliance can be severe. We help you determine whether you need to file, prepare accurate FBARs, and address any prior-year gaps.

Book a Consultation

What Is the FBAR?

The FBAR (Report of Foreign Bank and Financial Accounts), officially FinCEN Form 114, is an annual information return required of U.S. persons who have a financial interest in or signature authority over foreign financial accounts with an aggregate value exceeding $10,000 at any time during the calendar year. The FBAR is not a tax return — it is filed with the Financial Crimes Enforcement Network (FinCEN), not the IRS, though the IRS enforces compliance.

Many taxpayers are unaware of the FBAR requirement until they hear about it from a tax professional — or receive an IRS notice. The reporting obligation applies broadly: to U.S. citizens, green card holders, resident aliens, and even non-resident aliens who meet the substantial presence test. It covers bank accounts, brokerage accounts, mutual funds, and certain foreign insurance and retirement accounts. The key takeaway: if the aggregate maximum balance of your foreign accounts exceeded $10,000 at any point during the year, you likely need to file.

Penalties for failing to file FBARs are among the most severe in U.S. tax law. For non-willful violations, penalties can reach $10,000 (adjusted for inflation) per year. For willful violations, penalties can reach the greater of $100,000 (adjusted for inflation) or 50% of the account balance — per year. The IRS offers pathways to come into compliance voluntarily, but it is critical to address this before being contacted by the IRS.

Who Needs to File FBAR?

U.S. Citizens & Residents with Foreign Accounts

Any U.S. person with foreign financial accounts exceeding $10,000 in aggregate — regardless of where you live or where the accounts are held.

Expats & U.S. Citizens Abroad

Living abroad does not exempt you from FBAR. In fact, expats commonly have foreign accounts and are among the most likely to need to file.

New Immigrants & Green Card Holders

Accounts in your home country that you've maintained for years may now be reportable. Many new U.S. residents discover the FBAR requirement late.

Joint Account Holders with Foreign Relatives

Jointly held accounts with a foreign spouse, parent, or sibling count toward your $10,000 threshold — even if the money belongs to the other person.

Business Owners with Foreign Accounts

If your business has foreign accounts, or if you have signature authority over your employer's foreign accounts, you may have a separate FBAR obligation.

Taxpayers with Unfiled Prior-Year FBARs

If you've just learned about FBAR and realize you should have been filing, we can help you come into compliance through the IRS's voluntary disclosure or streamlined procedures.

When FBAR Filing Is Triggered

You maintain a bank account in your home country

Many new immigrants and green card holders keep accounts in their country of origin. Even a modest savings account at a foreign bank, when combined with other foreign accounts, can exceed the $10,000 threshold.

You have a foreign investment or brokerage account

Foreign brokerage, mutual fund, and securities accounts are reportable. The value of the holdings counts toward the $10,000 threshold.

You're a joint account holder with a foreign family member

Your name on a joint account with a parent, spouse, or sibling abroad makes the full account balance reportable on your FBAR — even if you consider the money "not yours."

You have a foreign pension or retirement account

Certain foreign pension accounts and retirement plans are considered foreign financial accounts for FBAR purposes. The treatment depends on the specific type of plan and how it is structured.

You discovered you should have been filing for years

Many people learn about FBAR from a tax professional, a news article, or a friend — and realize they have missed multiple years. The IRS provides paths to catch up without facing the maximum penalties, but it's important to act before the IRS contacts you.

You have signature authority over business or employer accounts

Even if the money isn't yours, having the ability to sign on or direct the disposition of funds in a foreign account may trigger an FBAR filing requirement.

What You Need to File an FBAR

How We Handle FBAR Filing

1

Account Inventory

We work with you to identify every foreign financial account you have a relationship with — including accounts you may not think of as "financial accounts," like foreign pensions or insurance policies with cash value.

2

Maximum Balance Calculation

For each account, we determine the maximum balance during the calendar year in the foreign currency, then convert to U.S. dollars using the Treasury year-end exchange rate. We aggregate across all accounts to confirm the filing threshold is met.

3

FBAR Preparation & E-Filing

We prepare the FBAR (FinCEN Form 114) with complete and accurate information for each reportable account and e-file it through the BSA E-Filing System. The FBAR is due April 15 with an automatic extension to October 15.

4

Prior-Year Compliance (if needed)

If you have missed prior-year FBARs, we evaluate your situation and recommend the appropriate compliance path — Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures, or Delinquent FBAR Submission Procedures — depending on your facts, residence, and the reason for non-compliance.

Common FBAR Mistakes

FBAR Pitfalls

  • Not knowing the FBAR exists — Many taxpayers simply don't know about FBAR. The IRS has increased enforcement in recent years, and foreign financial institutions are increasingly sharing account information with the U.S. under FATCA intergovernmental agreements.
  • Thinking the $10,000 threshold is per account — It's not. It's the aggregate of all your foreign accounts. Three accounts with $4,000 each is $12,000 — over the threshold. All three must be reported.
  • Forgetting about joint accounts — If your name is on a joint account, the full balance counts toward your threshold, even if it's shared with a non-U.S. person or the funds are not primarily yours.
  • Missing the deadline — While the FBAR has an automatic extension to October 15, missing this date without a reasonable cause explanation can result in penalties for late filing.
  • Not converting foreign currency correctly — The FBAR requires you to report the maximum account value in U.S. dollars during the year. The IRS provides an official year-end exchange rate; using other rates can cause discrepancies.
  • Assuming FBAR is the same as Form 8938 — FBAR and Form 8938 are separate requirements with different thresholds, different filing locations, and different penalties. Some taxpayers must file both. Filing one does not satisfy the other.

Frequently Asked Questions

What is the $10,000 threshold — per account or total?
The $10,000 threshold is based on the aggregate maximum balance of all your foreign financial accounts combined. If the sum of the highest balances across all foreign accounts exceeds $10,000 at any point during the year, you must file an FBAR reporting all of them — including accounts with very small balances. For example, three accounts with $4,000, $4,000, and $3,000 at their peaks total $11,000; all three must be reported.
What is the FBAR filing deadline?
The FBAR is due April 15 following the calendar year reported, with an automatic extension to October 15. No extension request is needed. The FBAR is filed electronically through the BSA E-Filing System, separately from your tax return.
What if I haven't filed FBARs for prior years?
There are options to come into compliance voluntarily. The IRS offers the Streamlined Filing Compliance Procedures for taxpayers whose failure to file was non-willful (you didn't know about the requirement). For those with more serious situations, other disclosure programs exist. It is critical to address this before the IRS contacts you — voluntary compliance offers significantly better outcomes.
What are the penalties for not filing?
For non-willful violations, the penalty is up to $10,000 (adjusted for inflation) per violation. For willful violations, penalties can reach the greater of $100,000 (adjusted for inflation) or 50% of the account balance. Criminal penalties are also possible. Coming into compliance voluntarily before IRS contact can help avoid or reduce these penalties.
What accounts must be reported on FBAR?
FBAR covers bank accounts, brokerage and securities accounts, mutual funds, certain foreign insurance policies with cash surrender value, and certain foreign pension and retirement accounts. Directly held foreign real estate is generally not reportable, but ownership through a foreign entity or trust may be. The test is whether you have a financial interest in or signature authority over the account.
Is FBAR the same as Form 8938?
No. They are separate requirements. FBAR is filed with FinCEN and has a $10,000 aggregate threshold. Form 8938 is filed with your tax return and has higher thresholds ($50,000-$600,000 depending on filing status and residence). The two forms overlap in some areas but differ in what assets they cover, what thresholds apply, and what penalties attach. Filing one does not satisfy the other. Many taxpayers with foreign accounts must file both.

Need Help with FBAR Filing?

Whether you're filing for the first time or need to catch up on prior years, we can help you get compliant.

Book a Consultation Upload Documents Securely

Or email us at [email protected]  |  Phone: [Phone Number]

IRS Circular 230 Disclosure: Any tax advice contained in this communication is not intended or written to be used, and cannot be used, for the purpose of avoiding federal tax penalties or promoting, marketing, or recommending any transaction or matter addressed herein.

Important: Do not send sensitive personal information such as Social Security numbers or banking details through unsecured forms or email. Use our secure client portal for document uploads. The information on this page is for general informational purposes only and does not constitute professional tax advice. Every taxpayer's situation is unique — please consult with a CPA regarding your specific facts and circumstances.