Foreign Bank account report
The IRS requires the annual filing of FinCEN Form 114 (“FBAR”) if the value of your foreign financial accounts exceeds a threshold.
Foreign Bank Account Report
What accounts do I need to report?
You’re required to report all foreign financial accounts, such as bank accounts, brokerage accounts, savings accounts, as well as certain life insurance policies and retirement accounts.
If you have more than one foreign account, you may be required to file an FBAR, even if the total value of your accounts never exceeded $10,000. For the $10,000 threshold, the IRS considers the highest balance of each account separately. If the total, when adding up the highest balances, exceeds $10,000, you’re required to file an FBAR.
The IRS requires you to report accounts you own separately, as well as accounts owned together with someone else. For example, an account owned together with a non-U.S. spouse must be reported on your FBAR. Furthermore, even accounts that aren’t yours must be reported on your FBAR, if you have signature authority over the account.
What’s the FBAR filing deadline?
Your FBAR for tax year 2025 is due on April 15, 2026. However, this deadline is automatically extended to October 15, 2026.
What to do if my FBAR is late?
The IRS acknowledges there are many Americans living abroad that may not have been aware about their filing obligations. If you meet certain requirements, you will not be subject to penalties. The IRS introduced two tax amnesty programs. The first is called Delinquent FBAR Submission Procedures. The second is called Streamlined Filing Compliance Procedures.
The Delinquent FBAR Submission Procedures are for taxpayers that do not need to amend their tax returns. If you have properly reported the income from the account for which you should have filed an FBAR, you’re not under examination by the IRS and have not already been contacted by the IRS, you generally qualify for these procedures.
If, in addition to not filing an FBAR, you also haven’t yet filed your U.S. tax return, you may qualify for the Streamlined Procedures. The most important requirement is that your failure is non-willful.
Depending on your specific facts and circumstances, you may qualify to correct for your non-compliance under the Streamlined Filing Compliance Procedures. If you would like to get a better understanding of the Streamlined Procedures, please schedule a consultation by contacting us today.
Whether you have never filed a U.S. tax return before, and have recently discovered under U.S. tax laws you are required to do so, or whether you have filed but are uncertain about having reported all your foreign assets correctly, we are here to help to get you compliant with U.S. tax laws.
If you have a financial interest in or signature authority over one or more foreign financial accounts and the aggregate value of those account exceeds $10,000 at any time during the calendar year (even for one day) you are required to file an FBAR with the U.S. Department of Treasury.
What are the penalties for not filing an FBAR?
If you meet the above mentioned requirements and take action once you’ve realized you should have filed an FBAR, the IRS will generally not impose a penalty. This is important, as the penalties for not filing an FBAR are serious. If the IRS determines your failure to file is non-willful (i.e. that you made an honest/accidental mistake), the penalty can be $10,000, per account and per year. The penalty for willful non-compliance can be $100,000 or 50% of the value of the account that should have been reported, whichever is higher. In other words, even if the IRS determines you’re non-willful in your failure to file an FBAR and you’ve missed just 2 accounts for 2 years, the penalty can be $40,000.
Have a question? Contact us.
Contact us with any questions you have about filing an FBAR. We specialize in the preparation of U.S. tax forms, including the FBAR, for Americans living abroad. Our tax professionals have filed FBARs for thousands of taxpayers. We have offices in Denver, as well as Germany, Switzerland, the Netherlands and the United Kingdom.
Frequently asked questions about the Fbar form
Who needs to file an FBAR and what types of accounts must be reported?
What happens if I file my FBAR late?
If you missed the FBAR deadline but meet certain requirements, the IRS may not impose penalties. There are two amnesty programs: Delinquent FBAR Submission Procedures (for those who don’t need to amend tax returns) and Streamlined Filing Compliance Procedures (for non-willful failures where a tax return may also be missing).
How do I determine if I meet the $10,000 FBAR filing threshold?
To determine if you need to file an FBAR, add together the highest balances of all your foreign financial accounts during the year. If the total of these highest balances exceeds $10,000—even if no single account held that amount alone—you are required to file an FBAR. This includes accounts you own jointly or accounts over which you have signature authority.
