Americans in Germany generally need to file an FBAR if the combined value of their reportable foreign financial accounts exceeds $10,000 at any point during the calendar year.
German checking, savings, and brokerage accounts are common examples, and the $10,000 threshold applies to all reportable foreign accounts combined, not to each account separately.
Opening a German bank, savings, or investment account can create additional US reporting obligations, even if the account generates little or no income.
Americans in Germany generally must file an FBAR (FinCEN Form 114) if the combined value of their reportable foreign financial accounts exceeds $10,000 at any point during the year. This includes accounts over which they have signature authority.
FBAR reporting is therefore an important part of US expat taxes in Germany, particularly for Americans who maintain several German bank or investment accounts.
Key Takeaways: FBAR for Americans in Germany
-
The FBAR threshold is $10,000 in aggregate, not $10,000 per account.
-
German checking, savings and brokerage accounts are commonly reportable.
-
An account can be reportable even if it earns no income.
-
Joint accounts and accounts over which you have signature authority may also need to be reported.
-
The FBAR is separate from your US income tax return and from Form 8938.
Quick Facts: FBAR Reporting for Americans in Germany
| If you have… | What it can mean for your FBAR |
| German checking account | Generally a reportable foreign financial account |
| German savings or time deposit | Generally reportable |
| German brokerage/Depot account | Generally reportable |
| Several accounts below $10,000 each | FBAR may still be required if their combined value exceeds $10,000 |
| Joint account with your spouse | May need to be reported at its full maximum value |
| Authority over a company account | Signature-authority reporting may apply |
| Account with no interest or income | Can still be reportable |
| Foreign accounts over $10,000 combined | Generally triggers an FBAR filing requirement |
| Higher-value foreign assets | Form 8938 may also need to be considered |
Who Needs to File an FBAR?
A US person generally needs to file an FBAR when two conditions are met:
You have a financial interest in or signature or other authority over at least one foreign financial account, and the aggregate value of your reportable foreign financial accounts exceeds $10,000 at any time during the calendar year.
For FBAR purposes, US persons include US citizens and residents.
This means moving to Germany does not remove the requirement. In fact, Americans living abroad are often more likely to encounter FBAR reporting because they naturally open accounts in their country of residence.
The account also does not need to generate taxable income.
A German account holding your salary or money for household expenses can still be reportable.
Which German Bank Accounts Are Reported?
Most ordinary accounts maintained with German financial institutions should be considered when determining whether you need an FBAR.
This commonly includes:
Girokonto
A German checking or current account used to receive your salary, pay rent and handle everyday expenses is generally a foreign financial account for FBAR purposes.
Savings Accounts
German savings and deposit accounts are generally reportable as well.
This includes accounts you may maintain separately from your everyday checking account.
Time Deposits
Fixed-term deposits and similar deposit accounts maintained with German financial institutions generally fall within the types of accounts covered by the FBAR rules.
The important point is that an account does not become exempt simply because it is used for savings rather than everyday transactions.
Do German Brokerage and Investment Accounts Go on the FBAR?
Generally, foreign securities and brokerage accounts are included within the types of financial accounts covered by the FBAR rules. That means a German Depot used to hold stocks, ETFs or other investments may need to be reported.
This is separate from the US tax treatment of the investments held inside the account.
For example, if your German Depot contains European ETFs, you may need to consider:
FBAR reporting for the brokerage account, and separately, Form 8621 reporting if any of the investments are PFICs.
Form 8938 may also apply if your foreign financial assets exceed the applicable threshold.
One German investment account can therefore create several different US reporting considerations.
How Does the $10,000 FBAR Threshold Work?
This is one of the most commonly misunderstood parts of the FBAR.
The threshold is not $10,000 per account.
Instead, you look at the combined value of all reportable foreign financial accounts.
For example, suppose during the year your maximum balances are approximately:
| German account | Maximum value |
| Checking account | $6,000 |
| Savings account | $3,500 |
| Brokerage account | $4,000 |
None of the accounts individually exceeds $10,000.
However, their combined maximum values are $13,500.
You would therefore exceed the FBAR threshold.
Once the threshold is met, you generally report all reportable foreign accounts—not only the account that caused you to exceed $10,000.
Not sure if your German accounts push you over $10,000?
Our US expat tax team can review your accounts and confirm whether you need to file an FBAR.
What Value Do You Report on the FBAR?
The FBAR asks for the maximum value of each account during the calendar year. For an account maintained in euros, you first determine its maximum value in euros during the year.
The amount is then converted to US dollars using the applicable year-end Treasury exchange rate for FBAR purposes.
This is different from simply taking the balance shown on December 31.
For example, if your German savings account reached €25,000 in July but had only €8,000 remaining at year-end, the relevant starting point for FBAR reporting is the maximum value during the year, not the December balance.
Keeping your annual German bank and brokerage statements can make this calculation much easier.
What About Joint German Bank Accounts?
Joint accounts can also be reportable.
If you jointly own a German bank account with your spouse or another person, you generally need to consider the entire maximum value of the account for FBAR reporting rather than reporting only your percentage of the balance.
There are special filing rules that can allow one spouse to report jointly owned accounts on behalf of the other spouse when the applicable requirements are met, including authorization using FinCEN Form 114a.
Your US income tax filing status does not by itself determine whether this spousal FBAR exception applies.
What If You Have Signature Authority Over a German Account?
You do not necessarily need to own the money in an account for FBAR reporting to become relevant.
The FBAR rules also cover certain accounts over which a US person has signature or other authority.
For example, you might be able to authorize payments from your German employer’s or company’s bank account even though the funds do not belong to you personally.
That account should still be considered when determining your FBAR reporting requirements.
This is particularly relevant for Americans who manage a German GmbH or UG and have authority over the company’s bank accounts.
Are German Pension Accounts Reported on the FBAR?
Foreign pension reporting can be more complicated because the answer depends on how the pension arrangement is structured.
Do not assume that every German pension is automatically an FBAR account, but do not automatically exclude a private pension or financial account simply because Germany treats it as a retirement arrangement.
The specific plan needs to be reviewed to determine whether you have a reportable foreign financial account.
Pensions can also create separate US tax and Form 8938 considerations even when the FBAR treatment differs.
Is the FBAR Part of Your US Tax Return?
No.
The FBAR is FinCEN Form 114, and it is filed electronically with the Financial Crimes Enforcement Network rather than attached to Form 1040.
However, your US income tax return asks questions about foreign financial accounts on Schedule B.
That means your FBAR and income tax return should be prepared consistently.
The FBAR generally has an April 15 due date, with an automatic extension to October 15. You do not need to file a separate extension request to receive the automatic FBAR extension.
FBAR vs. Form 8938: What’s the Difference?
The FBAR and Form 8938 are separate reporting requirements.
The FBAR is filed with FinCEN and focuses on foreign financial accounts. Form 8938 is an IRS form attached to your income tax return and covers specified foreign financial assets.
They also have different reporting thresholds.
Americans who qualify as living abroad generally have higher Form 8938 thresholds than taxpayers living in the United States.
However, filing one form does not automatically satisfy the other. Depending on your assets, the same German account can potentially appear on both your FBAR and Form 8938.
Don’t risk FBAR penalties.
Let a US expat tax professional prepare your FBAR and Form 8938 so they match your tax return. Avoid mismatched filings, missed foreign accounts, and unnecessary IRS headaches.
What Information Do You Need to File an FBAR?
For each potentially reportable German account, keep the account number, financial institution’s name and address, type of account and maximum value during the year.
You should also identify whether the account is individually owned, jointly owned or an account over which you only have signature authority.
For accounts denominated in euros, keep statements showing enough activity to determine the highest balance during the calendar year.
If you maintain several German accounts, gathering this information throughout the year can make FBAR preparation much easier.
