You generally need to file an FBAR if the combined value of your foreign financial accounts exceeds $10,000 at any point during the year and you have a financial interest in or authority over those accounts.
For Americans living abroad, FBAR reporting can apply to everyday bank accounts as well as certain investment, retirement, and other foreign financial accounts.
The $10,000 threshold is based on the combined value of your reportable accounts, which means you may need to file even when no single account exceeds $10,000.
Understanding which accounts are reportable is important because the rules are not limited to accounts that generate income. Joint accounts, accounts you have authority over, and certain foreign investment or retirement accounts can also create reporting obligations.
If you’d rather have a tax professional determine which accounts need to be reported and prepare FinCEN Form 114 for you, we provide FBAR filing service for current and prior-year foreign account reporting.
Key Summary: FBAR Reporting Requirements
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$10,000 aggregate threshold: The threshold applies to the combined value of your reportable foreign financial accounts.
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More than bank accounts: Brokerage, securities, and certain other foreign financial accounts may also need to be reported.
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Income is not required: An account can be reportable even if it earned no interest or other income.
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Ownership isn’t always required: Signature or other authority over a foreign account can create an FBAR reporting requirement.
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FBAR and Form 8938 are different: Depending on your circumstances, you may need to file one or both.
What is an FBAR?
The FBAR, or Report of Foreign Bank and Financial Accounts, is used to report certain financial accounts located outside the United States.
The official form is FinCEN Form 114, and it is filed electronically with the Financial Crimes Enforcement Network (FinCEN). It is separate from your federal income tax return.
The FBAR is an information-reporting requirement. Filing the form itself does not calculate or create US income tax.
Who Needs to File an FBAR?
You generally need to file an FBAR when all of the following apply:
- You are a US person for FBAR purposes.
- You have a financial interest in, or signature or other authority over, at least one foreign financial account.
- The aggregate value of all reportable foreign financial accounts exceeded $10,000 at any point during the calendar year.
You can therefore have an FBAR requirement even when no individual foreign account contains more than $10,000.
Not Sure If You Need to File an FBAR?
Our team of tax professionals can review your foreign accounts, determine what needs to be reported, and help you meet your FBAR requirements.
Who is Considered a US Person for FBAR Purposes?
A US person generally includes US citizens and residents, as well as domestic entities such as corporations, partnerships, LLCs, trusts, and estates.
Living abroad does not remove this requirement, so US citizens and residents overseas may still need to report qualifying foreign accounts.
How Does the $10,000 FBAR Threshold Work?
One of the most commonly misunderstood FBAR rules is the $10,000 threshold.
The threshold applies to the aggregate value of all reportable foreign financial accounts, not separately to each account.
For example:
| Foreign account | Maximum value |
|---|---|
| Bank account | $6,000 |
| Savings account | $3,500 |
| Investment account | $4,000 |
| Combined value | $13,500 |
Even though none of the accounts individually exceeded $10,000, you may have an FBAR filing requirement because their combined value exceeded the threshold.
If the aggregate threshold is exceeded, you generally report all reportable foreign accounts, including accounts with relatively small balances.
What If Your Accounts Exceeded $10,000 for Only One Day?
You can still have an FBAR filing requirement.
The threshold is based on whether the aggregate value of your foreign financial accounts exceeded $10,000 at any time during the calendar year.
It does not matter whether the balance remained above $10,000 for the entire year, a month, or only briefly.
Your December 31 balance therefore does not determine whether you have an FBAR requirement.
Which Foreign Financial Accounts Must Be Reported?
FBAR reporting can apply to more than traditional checking and savings accounts.
Common examples of potentially reportable foreign financial accounts include:
- Checking accounts
- Savings accounts
- Brokerage accounts
- Securities accounts
- Certain mutual fund accounts
- Certain foreign retirement or pension accounts
- Other financial accounts maintained by foreign financial institutions
Whether a particular investment, pension, insurance product, or other foreign asset is reportable depends on how the asset is held and the applicable FBAR rules.
The location of the financial account is also important. Generally, an account maintained by a financial institution located outside the United States is considered a foreign financial account.
Make Foreign Account Reporting Easier
Have multiple foreign accounts or unsure which ones belong on your FBAR? We can review your accounts and prepare FinCEN Form 114 for you.
Does a Zero-Balance Foreign Account Need to Be Reported?
Potentially, yes.
An account does not automatically become exempt from FBAR reporting simply because it had a zero balance at the end of the year.
What matters is whether the account is reportable and whether you met the overall FBAR filing requirement during the calendar year.
If you are required to file an FBAR, an account may still need to be included even if its balance was very low or reached zero during the year.
Does a Foreign Account Have to Earn Income to Be Reported?
No.
FBAR reporting is based on your foreign financial accounts and their values, not on whether those accounts generated taxable income.
For example, a foreign savings account may still need to be reported even if:
- It earned no interest.
- You did not withdraw money.
- You did not receive taxable income from it.
- You only used it for ordinary living expenses.
Foreign income reporting and FBAR reporting are separate requirements.
What Does “Financial Interest” Mean for FBAR Purposes?
The FBAR rules apply when you have a financial interest in a foreign financial account.
The most straightforward example is an account where you are the owner of record or hold legal title.
However, financial interest can also arise in certain situations where another person or entity holds legal title to an account on your behalf or where you have specified ownership interests in an entity that owns foreign financial accounts.
This can be particularly important for Americans who own foreign companies, partnerships, trusts, or other entities.
What is Signature or Other Authority?
You do not necessarily need to own the money in a foreign account to have an FBAR reporting requirement.
FBAR rules can also apply if you have signature or other authority over a foreign financial account.
For example, an American working abroad may have authority over a foreign employer’s corporate bank account even though the funds belong entirely to the employer.
Whether that account needs to be reported depends on the circumstances and whether an exception applies.
How Are Joint Foreign Accounts Reported?
Jointly owned foreign accounts can create an FBAR reporting requirement for each US person who has a financial interest in the account.
Generally, each joint owner reports the entire value of the jointly owned account, rather than only their percentage of ownership.
Special rules apply to married couples. In certain circumstances, spouses can avoid filing separate FBARs for jointly owned accounts when the requirements are met and FinCEN Form 114a is completed.
Do Children Have to File an FBAR?
Yes, children can have an FBAR filing requirement.
The FBAR rules do not provide a general exemption simply because the account owner is a minor.
If a child meets the FBAR reporting requirements, the child is generally responsible for filing. If the child cannot file because of age or another reason, a parent or guardian may need to file on the child’s behalf.
This can be relevant when a US citizen child living abroad has local savings, investment, or other financial accounts.
What Foreign Accounts Do Not Have to Be Reported?
Not every foreign financial account is reportable.
Certain exceptions apply, including some accounts:
- Owned by US governmental entities
- Owned by international financial institutions
- Maintained at US military banking facilities
- Held in certain US individual retirement accounts
- Held in certain US retirement plans
- Held in certain trusts where another US person reports the account
Other exceptions and special rules may apply depending on the account and the person who owns or controls it.
You should therefore not assume that an account is exempt simply because it is a pension, retirement account, business account, or jointly owned account.
Need Professional Help With Your FBAR?
Whether you’re filing for the current year or dealing with missed FBARs from previous years, our expat tax professionals can help you determine the appropriate next steps.
How Do You Determine the Value of Foreign Accounts?
Foreign accounts are reported in US dollars.
Generally, you determine the maximum value of each account during the calendar year and convert the foreign currency amount into US dollars using the applicable FBAR exchange rate.
This is different from simply converting the December 31 account balance.
Once you have determined which accounts need to be reported, how to file an FBAR involves gathering the required account details, calculating the maximum values, converting them to US dollars, and submitting FinCEN Form 114 electronically.
FBAR vs. Form 8938: Are They the Same?
No. The FBAR and Form 8938 are separate foreign financial reporting requirements.
The FBAR (FinCEN Form 114) is filed with FinCEN and focuses primarily on foreign financial accounts.
Form 8938, Statement of Specified Foreign Financial Assets, is filed with your federal income tax return and can cover a broader range of specified foreign financial assets.
The filing thresholds are also different. The FBAR generally uses a $10,000 aggregate foreign-account threshold, while Form 8938 thresholds depend on factors such as your filing status and whether you live in or outside the United States.
Some taxpayers must file both forms. Filing one does not automatically satisfy the other requirement.
Does Filing an FBAR Mean You Owe US Tax?
No. Filing an FBAR does not itself create a tax liability.
The FBAR is an information-reporting form used to disclose qualifying foreign financial accounts.
However, income generated by those accounts, such as interest, dividends, or investment gains, may need to be reported separately on your US income tax return.
You could therefore have an FBAR filing requirement without owing additional US tax, or you could have both an FBAR requirement and taxable foreign income.
When is the FBAR Due?
The FBAR is generally due April 15 following the calendar year being reported.
If you miss the April 15 deadline, you receive an automatic extension to October 15. You do not need to submit a separate extension request for the FBAR.
This differs from the extension rules for a federal income tax return.
What Are the Penalties for Not Filing an FBAR?
Failing to file a required FBAR can result in significant penalties, depending on the circumstances and whether the violation was considered non-willful or willful.
In 2026, the IRS removed its Delinquent FBAR Submission Procedures, which previously provided certain qualifying taxpayers with a specific path for filing overdue FBARs without penalties. As a result, taxpayers with missed filings should not assume that simply submitting late FBARs will automatically avoid penalties.
