🌍 Who Files FBAR

Who Needs to File an FBAR?
The $10,000 Rule

You file an FBAR if you are a US person and the combined maximum value of all your foreign financial accounts exceeded $10,000 at any single point during the calendar year. Not interest earned. Not income. Just the aggregate balance.

The $10,000 aggregate, in plain terms

Look at every foreign account you owned or controlled during the year. For each one, find the highest balance it ever held β€” even for one day, even from a wire transfer that arrived and was spent the next morning. Add those peak balances together. If that total exceeds $10,000 at any single point, you file.

Example: a UK checking account and a EUR savings account
  • UK checking peak balance (March): $7,200
  • EUR savings peak balance (March): $4,500
  • Aggregate peak: $11,700

Even though no single account crossed $10,000, the aggregate did. FBAR required.

Who counts as a "US person" for FBAR

Broader than US citizenship. Status follows you abroad.

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US citizens

Anywhere in the world. Living in Tokyo or Toledo does not change the FBAR obligation. The filing applies as long as you hold US citizenship.

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Green card holders

Lawful permanent residents are US persons for FBAR purposes regardless of where they physically live, until they formally abandon the green card.

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Resident aliens (183-day test)

Anyone who meets the IRS substantial presence test β€” roughly 183 weighted days in the US over a three-year window. Visa status alone does not matter; physical presence does.

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US entities

Corporations, partnerships, LLCs, trusts, and estates formed under US law. The entity itself files an FBAR if it has foreign accounts crossing the threshold.

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Signature authority holders

If you can authorize transactions on a foreign account β€” even if the money is not yours β€” you may have an FBAR obligation. Common for corporate officers and treasurers.

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Fiduciaries

Executors of estates, trustees, and guardians who control foreign accounts on behalf of others. The duty attaches to whoever has authority over the account.

What counts as a foreign financial account

Anything held at a financial institution outside the United States, US territories, or Indian reservations. Location of the institution matters, not the currency.

Counts for FBAR
  • Foreign bank accounts (checking, savings)
  • Foreign brokerage and securities accounts
  • Foreign mutual funds
  • Cash-value insurance and annuity policies held abroad
  • Foreign-held retirement accounts (most)
  • Online banks based outside the US (Wise, Revolut, N26, etc.)
Does not count
  • Foreign real estate held directly
  • Physical gold, art, or collectibles abroad
  • US-based accounts holding foreign currency
  • Accounts at US branches of foreign banks (Chase, HSBC US)
  • Personal loans to individuals abroad

FBAR vs. FATCA Form 8938

These get confused constantly. They are separate filings. Many US persons must file both.

FBAR (FinCEN Form 114) FATCA (Form 8938)
Filed with FinCEN, via BSA E-Filing System IRS, attached to your 1040
Threshold $10,000 aggregate at any point $50,000 – $600,000 depending on filing status and residency
Scope Foreign financial accounts Foreign financial assets (broader β€” includes some non-account assets)
Deadline April 15, with auto extension to October 15 Your tax return deadline
Penalty Up to $16,536 non-willful, $165,353 or 50% willful Up to $10,000 initial, up to $50,000 continued

If you need to file, you need a reminder system

Most filers do not learn they had an obligation until they have already missed several years. That is the worst position to be in. See the penalties and recovery page for what to do if that is you.

If you have confirmed you need to file going forward, set a recurring April 15 reminder so next year's filing is not a question of whether you remembered. See the FBAR reminder pillar for the full overview.

Set a yearly FBAR reminder β€” fires every April automatically.

Create a Reminder

Done in seconds. No sign-up required.

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FBAR eligibility questions

Do I need to file an FBAR if I am not a US citizen?

Possibly. Green card holders and resident aliens (anyone meeting the substantial presence test of 183+ days in the US during the year) are US persons for FBAR purposes. If your foreign accounts aggregated over $10,000 at any point, you file.

What counts as a foreign financial account for FBAR?

Bank accounts, savings accounts, brokerage and securities accounts, mutual funds, certain insurance and annuity policies with cash value, and accounts held at any foreign financial institution. Foreign real estate and physical assets held abroad do not count. Cryptocurrency on a foreign exchange is in a gray area as of 2026.

Do joint accounts count toward the $10,000 threshold?

Yes β€” the full balance of the joint account counts toward each owner's aggregate. Two spouses with a $15,000 joint foreign account each have $15,000 attributed to them for FBAR purposes, not $7,500 each. Both file their own FBAR.

I have signature authority but no financial interest. Do I file?

Yes, if you have signature or other authority over an account whose aggregate value crossed $10,000 β€” even if the money is not yours. This often applies to corporate officers, treasurers, and executors. A separate FinCEN extension to April 15, 2027 applies for some signature-only filers.

My account briefly crossed $10,000 then dropped back. Do I still file?

Yes. The threshold is the maximum value at any single point during the calendar year. A one-day spike above $10,000 because of a wire transfer or currency fluctuation triggers the filing obligation. The current balance is irrelevant.

What is the difference between FBAR and FATCA Form 8938?

FBAR (FinCEN Form 114) goes to FinCEN through the BSA E-Filing System, with a $10,000 aggregate threshold, separate from your tax return. Form 8938 (FATCA) goes to the IRS attached to your 1040, with higher thresholds ($50,000+ depending on filing status and residency). Many filers must file both.

Does FBAR apply to US persons living abroad?

Yes. US citizenship and green card status follow you globally. A US citizen living in Germany with a German checking account that exceeded $10,000 at any point in 2025 has the same April 15, 2026 FBAR obligation as someone living in Ohio.

Now You Know You Have to File. Don't Forget.

Set a recurring FBAR reminder. We email you before April 15 every year, plus follow-ups if you do not mark it done. Free, no account.

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