International Tax

FBAR and FATCA: Reporting Foreign Bank Accounts to the US

US persons with foreign financial accounts have two separate reporting obligations. Confusing them — or skipping them — has bankrupted otherwise compliant taxpayers.

FBAR — the $10,000 trigger

If the aggregate value of all your foreign accounts exceeded $10,000 at any point during the year, you must file FinCEN Form 114 (FBAR). Threshold is total across all accounts, not per account.

Who counts as 'US person'

  • US citizens (anywhere in the world)
  • US resident aliens (green card holders, substantial-presence test)
  • US entities (corporations, partnerships, LLCs, trusts)

What's a 'foreign financial account'

  • Bank accounts at non-US institutions
  • Brokerage accounts at non-US firms
  • Foreign mutual funds and pensions
  • Accounts with signature authority (employer accounts) — yes, even without ownership
  • Foreign-issued life insurance with cash value

How and when to file FBAR

Filed electronically on the FinCEN BSA E-Filing portal — separate from your tax return. Due April 15 with an automatic extension to October 15. No income reporting; just account info and max balance.

FATCA Form 8938 — different thresholds

Filed WITH your tax return when foreign assets exceed:

FilerEnd of yearAny point during year
Single, US-resident$50,000$75,000
MFJ, US-resident$100,000$150,000
Single, abroad$200,000$300,000
MFJ, abroad$400,000$600,000

The penalties are brutal

  • Non-willful FBAR: up to $10,000 per violation (per account, per year — courts split)
  • Willful FBAR: greater of $100,000 or 50% of account balance per year
  • Form 8938: $10,000 + $10,000 per 30 days after IRS notice, max $50,000

Streamlined compliance for past mistakes

The IRS Streamlined Filing Procedures let non-willful non-filers come into compliance with reduced penalties (sometimes zero for those living abroad). Talk to an international tax attorney — this is one area where DIY usually backfires.

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