FBAR (FinCEN 114) Filing: Who Must File and When
FBAR, the Foreign Bank Account Report, formally FinCEN Form 114, is one of the most commonly missed US tax obligations for Americans abroad. If the combined maximum value of all your foreign financial accounts exceeded $10,000 at any point during the calendar year (even for a single day), you are required to file. The penalties for non-compliance are severe, and the IRS enforcement has intensified significantly over the past decade.
The $10,000 threshold explained
The filing threshold is based on the aggregate maximum value of all foreign financial accounts at any point during the year, not the ending balance, and not a per-account threshold. If you have three accounts with £3,000, €2,500, and AUD 8,000, you must aggregate them all (converting to USD) to determine whether the combined maximum exceeded $10,000. Accounts include checking accounts, savings accounts, investment accounts, crypto accounts at foreign exchanges, pension accounts, and even accounts you have signature authority over (e.g. an employer's account).
FBAR deadlines for 2025 (2024 tax year)
The FBAR deadline is April 15, 2025 for the 2024 tax year, the same as the regular US tax deadline. Americans abroad receive an automatic extension to October 15, 2025, no form required. The FBAR is filed electronically through FinCEN's BSA E-Filing System (not with the IRS), and it is separate from your Form 1040. You cannot request a further extension beyond October 15.
Penalties for non-filing or late filing
FBAR penalties are among the most severe in the US tax system. Non-wilful violations (you didn't know you had to file) carry a penalty of up to $10,000 per violation per year. Wilful violations can result in penalties of the greater of $100,000 or 50% of the account balance per violation per year, plus potential criminal charges. The IRS Streamlined Filing Compliance Procedures allow qualifying non-wilful non-filers to catch up with penalties waived. Coming forward voluntarily is strongly recommended before the IRS contacts you.
Common accounts that trigger FBAR
Many people don't realise that foreign accounts include: UK current and savings accounts, EU bank accounts in any currency, foreign brokerage accounts (e.g. a German depot or French PEA), crypto held at foreign exchanges (Binance non-US, etc.), foreign PayPal or Revolut accounts with significant balances, and foreign pension accounts (though some treaty-protected pensions may have different treatment). If you're an authorised signatory on an employer's foreign account, that account counts toward your personal threshold too.
FBAR vs FATCA Form 8938
FBAR and Form 8938 (FATCA) are different and both may be required. FBAR applies to foreign financial accounts above $10,000 aggregate. Form 8938 applies to specified foreign financial assets and has higher thresholds ($50,000 for US residents, $200,000 for those living abroad). Both must be filed independently when the thresholds are met. They have overlapping but not identical scope, some assets (e.g. foreign real estate owned directly) appear on 8938 but not FBAR.
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Frequently asked questions about FBAR (FinCEN 114) Filing: Who Must File and When
Is FBAR part of my tax return?
No. FBAR (FinCEN 114) is filed separately through FinCEN's BSA E-Filing System, not with the IRS and not as part of Form 1040. However, the deadline is the same as your tax return (April 15, automatically extended to October 15 for those abroad).
Do I need to file FBAR if my balance was briefly over $10,000?
Yes. The threshold is based on the highest aggregate balance at any point during the year, not the average or year-end balance. Even a single day over $10,000 triggers the filing requirement.
I haven't filed FBAR in years, what should I do?
Don't panic. The IRS Streamlined Foreign Offshore Procedures are designed for non-wilful non-filers like you. You file 3 years of amended returns and 6 years of FBARs, pay any back taxes owed, and penalties are waived. You must act before the IRS contacts you. Our Catch-Up packages handle this.
Does FBAR apply to cryptocurrency held on foreign exchanges?
Currently yes, the FinCEN has signalled that cryptocurrency at foreign exchanges counts as a reportable foreign financial account. This area is evolving, but the safest approach is to report. Crypto held in self-custody (not on an exchange) is not currently FBAR-reportable.