What the FBAR is
FBAR stands for Report of Foreign Bank and Financial Accounts (FinCEN Form 114). It is not a tax form — it is a financial reporting form filed with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury. It is filed separately from your tax return, through a separate system.
Who must file: any U.S. person (citizen, green card holder, resident alien, and certain trusts and entities) who had a financial interest in, or signature authority over, one or more foreign financial accounts whose aggregate maximum value exceeded $10,000 at any point during the calendar year.
If you have a checking account with a peak balance of $6,000 and a savings account with a peak balance of $5,500 at the same point in time, your combined balance exceeded $10,000. FBAR is required. Each account is reported separately on the form.
Step 1 — Identify all your foreign financial accounts
Work through each category below. Check every box that applies to your situation.
Foreign bank checking accounts
Any account at a non-U.S. bank where you deposit salary, make payments, or hold funds for daily use. Includes accounts at international branches of U.S. banks (e.g., Citibank India, HSBC UAE) — these are foreign accounts for FBAR purposes.Foreign savings accounts
Savings accounts, high-yield accounts, term deposits, and fixed deposits at any foreign financial institution.Foreign brokerage and investment accounts
Any account at a non-U.S. brokerage, investment platform, or fund house where you hold stocks, bonds, ETFs, or mutual funds.Foreign pension and retirement accounts
Individually held pension accounts (e.g., iDeCo in Japan, Riester in Germany, SIPP in UK, RRSP in Canada, Super funds in Australia) are generally reportable. Government-run defined benefit plans may be different — consult a professional.Foreign money market accounts and CDs
Any time-deposit, certificate of deposit, or money market account at a foreign institution.Foreign cryptocurrency accounts
If held on a foreign exchange (not a U.S.-based platform), these may be reportable. The IRS and FinCEN are still developing formal guidance but the conservative position is to include them.Accounts where you have signature authority but no ownership
If you are an authorized signatory on a foreign business account, employee benefit account, or trust account — even if the money is not yours — this may require FBAR reporting.Foreign e-wallet or fintech accounts with stored balances
GCash, PayTM, Paytm, Maya, GrabPay balances held at a foreign financial institution. If they function like a bank account and hold a balance, include them in your threshold calculation.Step 2 — Calculate the threshold
For each account, find the highest balance at any single point during the year — not the average balance, not the year-end balance. The IRS uses the annual maximum.
Use the IRS official exchange rates to convert foreign currency balances to USD. The IRS publishes these rates at irs.gov/businesses/corporations/yearly-average-currency-exchange-rates. Use the rate for the year in which the account balance occurred.
| Account | Institution | Currency | Peak balance (local) | Exchange rate | Peak balance (USD) |
|---|---|---|---|---|---|
| Checking | ________________ | ____ | ____________ | ____________ | ____________ |
| Savings | ________________ | ____ | ____________ | ____________ | ____________ |
| Investment | ________________ | ____ | ____________ | ____________ | ____________ |
| Pension | ________________ | ____ | ____________ | ____________ | ____________ |
| Other | ________________ | ____ | ____________ | ____________ | ____________ |
| Total (add all USD peak balances) | ____________ | ||||
Even if the combined balance drops below $10,000 by December 31, FBAR is still required if it exceeded $10,000 at any earlier point in the year.
Step 3 — Gather account information for each reportable account
For every account that must be reported, collect the following before you file:
Name of the foreign financial institution
Full legal name as it appears on your statements, not just the common name.Account number
The full account number. For some accounts (IBAN format), use the full IBAN.Country where the account is held
The country where the financial institution is located, not necessarily where you are located.Maximum value during the year (in USD)
The highest balance at any point during the calendar year, converted to USD using official IRS exchange rates.Type of account
Bank (deposit), securities (brokerage), or other.Step 4 — File the FBAR
The FBAR is filed electronically through the BSA E-Filing System at bsaefiling.fincen.treas.gov — not through the IRS or your tax software.
- Deadline: April 15, with an automatic extension to October 15 (no request needed)
- Cost: Free to file
- Software: Most major expat tax software (H&R Block Expat, TurboTax Expat, Greenback) can prepare the FBAR and submit it electronically
- Joint filers: Spouses with joint accounts can file a single joint FBAR if all reportable accounts are jointly owned. If either spouse has individually owned accounts, separate FBARs are required.
Penalties for non-filing
| Type of violation | Maximum penalty |
|---|---|
| Non-willful failure to file (per violation) | $10,000 |
| Willful failure to file (per violation) | Greater of $100,000 or 50% of account balance |
| Negligent violation (per violation) | $500 |
| Pattern of negligence | $50,000 |
If you have non-willfully failed to file FBARs for prior years, the IRS Streamlined Offshore Procedures allow you to come into compliance by filing six years of back FBARs with no non-willful penalties. Do not simply start filing from this year forward without addressing prior years.
Common FBAR mistakes
- Not counting pension accounts: Most individually held foreign pension accounts (iDeCo, Riester, RRSP, ISA, Super) count toward the threshold.
- Using year-end balances instead of peak balances: The threshold uses the highest balance at any point in the year, not December 31.
- Not converting at IRS rates: Using Google's exchange rate or your bank's rate instead of the official IRS annual average.
- Filing with your tax return: The FBAR is a separate filing through FinCEN's system, not filed with or attached to your Form 1040.
- Assuming joint accounts are only one spouse's responsibility: Both spouses may need to report unless filing a joint FBAR.
- Forgetting accounts with signature authority: If you are a signatory on a company or trust account, it may need to be reported even if you don't own the funds.
Use the free FBAR Threshold Checker to monitor your combined foreign account balances throughout the year.
This document is educational content from ClearedExpat — written from direct expat filing experience, not as professional tax advice. Verify important decisions with a qualified tax professional who knows your complete situation. Full disclaimer →