FBAR Filing — FinCEN Form 114
If the combined maximum value of all your foreign financial accounts exceeded $10,000 at any point during the year, you are required to file FinCEN Form 114 — the FBAR. This is one of the most commonly missed US compliance requirements for Americans abroad. The penalties for wilful non-filing can reach 50% of the account balance per year. Our Expat and Investor packages include FBAR filing.
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- ✓Everything in Premier
- ✓Foreign Earned Income Exclusion (Form 2555)
- ✓Foreign Tax Credit (Form 1116)
- ✓FBAR filing (FinCEN 114) included
- ✓Everything in Expat
- ✓Schedules D & E for investments and rentals
- ✓Foreign asset reporting (Form 8938)
- ✓FBAR filing (FinCEN 114) included
Frequently asked questions about FBAR Filing — FinCEN Form 114
What counts as a foreign financial account for FBAR?
Foreign bank accounts, savings accounts, investment brokerage accounts, pension accounts at foreign institutions, crypto held at foreign exchanges, and accounts you have signature authority over (such as an employer's business account). The $10,000 threshold is an aggregate across all accounts.
What is the FBAR deadline?
April 15, with an automatic extension to October 15 for all filers (no form required). This is the same timeline as the US tax return. FBAR cannot be extended beyond October 15.
What are the penalties for not filing FBAR?
Non-wilful violations: up to $10,000 per violation per year. Wilful violations: the greater of $100,000 or 50% of the account balance per violation per year, plus potential criminal penalties. The distinction between wilful and non-wilful matters enormously.
I haven't filed FBAR in several years — what should I do?
The IRS Streamlined Foreign Offshore Procedure allows qualifying non-wilful non-filers to catch up on 3 years of returns and 6 years of FBARs with penalties waived. This is far better than waiting for the IRS to discover the delinquency.
Is FBAR the same as Form 8938 (FATCA)?
No. They're separate filings with different thresholds and purposes. FBAR covers foreign financial accounts over $10,000 aggregate. Form 8938 covers specified foreign financial assets with higher thresholds ($50,000 for US residents, $200,000 for those living abroad). Both may be required.
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