Expat tax · FinCEN Form 114
FBAR filing is generally required of any US person whose foreign accounts add up to more than $10,000 at their highest.
The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. You e-file it with FinCEN, the Treasury’s Financial Crimes Enforcement Network, through its BSA E-Filing System. It is not filed with the IRS or attached to your tax return.
Updated · Sources
The FBAR, as of 2026
- $10,000
- is the reporting threshold, applied to the highest values of all your foreign accounts added together.
- April 15
- is the due date for the previous calendar year’s FBAR. FinCEN extends it to October 15 automatically.
- $16,536
- is the largest non-willful penalty per late FBAR, for penalties assessed in 2026.
The $10,000 is set by regulation and is not indexed for inflation. A due date on a weekend or legal holiday moves to the next business day.
Do the FBAR filing requirements apply to you?
You must file an FBAR for any calendar year in which all four of these are true. A few exceptions, set out in the FAQs below, remove FinCEN’s reporting duty even then.
You are a US person
US citizens and US residents are US persons, including minor children. So are companies, partnerships, LLCs, trusts and estates formed under US law. A disregarded LLC must still file its own FBAR when it meets these four tests.
You have a financial interest or signature authority
A financial interest usually means your name is on the account, alone or jointly. It also covers accounts held by your agent or nominee, a company you own more than half of, or certain trusts. Signature authority means you can move the account’s assets, alone or with someone else, by instructing the bank or broker directly.
The account is a financial account abroad
Bank, securities and other financial accounts count when they are located outside the United States. Whether the account earned any income does not matter.
Your accounts’ highest values total more than $10,000
Take the highest value each account reached in the calendar year, in US dollars. If their sum is more than $10,000, the FBAR is due for that year.
A green card makes you a US resident for the FBAR, and so does passing the substantial presence test. Your accounts back home then count like any other foreign account.
Three accounts under $10,000 can still cross the FBAR threshold.
Checking account, highest in March
$6,000
Savings account, highest in August
$3,500
Brokerage account, highest in December
$1,500
Most held on any one day
$9,000
The accounts peaked at different times, so this is the most they ever held together.
The FBAR total
$11,000
FinCEN’s instructions add each account’s highest value, even from different months. The total is over $10,000, so an FBAR is due, and it lists all three accounts.
All amounts are round illustrations already in US dollars, so no exchange rate applies.
Which foreign accounts go on the FBAR form?
| Reported | Not reported | |
|---|---|---|
| Bank accounts | At a foreign bank, or a US bank’s branch abroad | At a foreign bank’s branch in the US Or at a US military banking facility abroad |
| Investments | Brokerage accounts and foreign mutual funds | Foreign shares you hold directly Foreign hedge funds and private equity funds are not reported either |
| Insurance and benefits | Life insurance or annuities with a cash value | Social security-type benefits from a foreign government |
| Through a company | Accounts of a company you own over 50% of | Your stake in the company itself |
Real estate, foreign cash, precious metals and art you hold directly are not accounts, so they stay off the FBAR. The FBAR rule does not list crypto accounts. An account that holds only crypto may not be reportable for now.
Which FBAR rules do people most often miss?
Reporting the year-end balance
Each account goes on the FBAR at its maximum value for the year, not its December 31 balance. FinCEN’s FBAR instructions accept periodic statements that fairly show the peak. Convert each peak at the Treasury’s exchange rate for December 31, then round up to the next dollar.
Answering “No” on Schedule B
Line 7a of Schedule B (Form 1040) asks if you had a financial interest in, or signature authority over, a foreign account. Check “Yes” even if no FBAR is due, then answer the follow-up question on whether you must file one.
Relying on your spouse’s FBAR
Each owner of a joint account reports its full value. One spouse can file for both only if the other’s foreign accounts are all joint with the filer, and both sign Form 114a. That FBAR must be filed on time. A joint tax return does not change these rules.
Forgetting accounts you can sign on at work
You must report signature authority over an employer’s foreign account, even with none of your own money in it. Officers and employees of US-listed companies, and of federally examined banks and brokers, are generally exempt. That exemption does not apply if you also have a financial interest in the account.
Leaving out a child’s accounts
A child who is a US person is generally responsible for their own FBAR, once their accounts pass the threshold. If the child cannot file it, a parent or guardian must file and sign it for them.
Missing FBARs from earlier years
If the IRS has not contacted you and you are not under investigation, it says to file late FBARs now and explain why. The statute of limitations on a civil FBAR penalty is six years. If you also owe returns, the Streamlined filing compliance procedures may cover both.
The CPA who prepares your US tax return also handles your FBAR filing online.
Valim’s CPAs file FBARs and US tax returns for Americans abroad and for US residents with accounts back home.
- We value each account at its peak, then file your FinCEN Form 114 once you sign Form 114a. Your instant quote prices each account you list on the FBAR.
- We prepare your Form 1040 with Schedule B, and check your assets against Form 8938’s separate thresholds.
- We prepare late FBARs for years you missed, and any returns still owed for those years.
- We plan estimated payments on foreign income.
- If the IRS writes about a return we prepared, we answer within your fee.
- Individual return
- from $195
- Business return
- from $495
We quote a flat fee before work starts. We do not bill hourly.
FBAR questions.
Do I need to file an FBAR if my accounts are under $10,000?
You need no FBAR if the highest values of all your foreign accounts add up to $10,000 or less. If each account is under $10,000 but their highest values together pass it, you still file. Each account counts at its maximum value for the year, even if the maximums came months apart. Your tax return still needs a “Yes” on Schedule B, line 7a, if you had any foreign account.
Who is exempt from FBAR reporting?
IRA owners and 401(a), 403(a) or 403(b) plan participants are exempt for foreign accounts held by the IRA or plan. A trust beneficiary is exempt when a US trustee files an FBAR listing the trust’s accounts. A spouse is exempt if all their foreign accounts are joint with the other spouse, who files on time, and both sign Form 114a. A company named in its parent’s consolidated FBAR does not file its own. Anyone who is not a US person, such as a foreign national who fails the FBAR’s residency tests, has no FBAR to file.
Do I need to file an FBAR every year?
Yes, you file an FBAR for every calendar year in which your foreign accounts’ highest values together pass $10,000. Each FBAR is due April 15 of the following year, with an automatic extension to October 15. Keep the records for each account, including its maximum value, for five years.
Do I report both accounts if only one is over $10,000?
Yes, you list both accounts on the FBAR once their highest values together pass $10,000. The IRS gives this exact case as an example. Every other foreign account you have goes on the report too. With 25 or more accounts, you give only their number and basic details, and the full list if asked.
What is the penalty for a late FBAR?
A late FBAR that was not willful can bring a civil penalty of up to $16,536, for penalties assessed on or after January 17, 2025. The Supreme Court’s 2023 Bittner decision applies that cap per late report, not per account. The Streamlined procedures page covers the other penalties and how to catch up on missed years.
Is the FBAR the same as Form 8938?
No, the FBAR and Form 8938 are separate foreign account reporting rules, and many people must file both. The FBAR is a Bank Secrecy Act report that you e-file with FinCEN, part of the Treasury. Form 8938 is an IRS form attached to your income tax return, listing your specified foreign financial assets. Its thresholds start at $50,000 for a single filer in the US and $200,000 for one living abroad. Each form covers some assets the other leaves out.
Sources
- 31 U.S.C. § 5314, Records and reports on foreign financial agency transactions
- 31 C.F.R. § 1010.350, Reports of foreign financial accounts
- FinCEN, BSA Electronic Filing Requirements for FinCEN Form 114 (Release January 2017, v1.4)
- P.L. 114-41, § 2006(b)(11), due date of FinCEN Report 114
- IRS, Report of Foreign Bank and Financial Accounts (FBAR)
- IRS, Comparison of Form 8938 and FBAR requirements
- IRS, Instructions for Schedule B (Form 1040) (2025)
- 31 U.S.C. § 5321, Civil penalties
- 31 C.F.R. § 1010.821, Penalty adjustment and table
- Bittner v. United States, 598 U.S. 85 (2023)
- 26 U.S.C. § 7701, Definitions
- 26 U.S.C. § 6038D, Information with respect to foreign financial assets
Reviewed and updated September 2026. General information, not advice for your situation.