FBAR for U.S. Expats — Accounts, Thresholds, Mistakes
Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks
The FBAR — the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 — is an annual disclosure of financial accounts held outside the United States, required whenever their combined maximum value exceeds $10,000 at any point in the year. For an expat, nearly every account is foreign, so the FBAR is less an exception than a fixture of the annual return.
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Which accounts count for an expat?
Any account at a non-U.S. financial institution over which you have ownership, joint ownership, or signature authority: checking and savings, brokerage and investment accounts, foreign pension and retirement accounts you can direct, cash-value life insurance, and prepaid cards with a stored balance. The threshold is the total of all accounts at their highest points during the year — five accounts of $2,500 each trigger it.
Which expat accounts get missed?
- Pension and retirement accounts. Most foreign personal and defined-contribution plans are reportable; many expats assume "retirement" means exempt.
- Joint accounts with a non-U.S. spouse. You report the full account value, not your half, even though your spouse has no U.S. obligation.
- Employer accounts you can sign on. Signature authority counts, even with no ownership — the company payroll account, a client trust account.
- Children's accounts you control, and accounts held by a foreign company you own more than half of.
- Accounts closed mid-year, which are reported for that year at their maximum value while open.
- Cryptocurrency on foreign exchanges — not currently required on its own, but an account holding both fiat and crypto is reportable for the fiat.
How is the maximum value determined?
The highest balance during the year, converted to U.S. dollars at the Treasury's year-end exchange rate for the reporting year. Statements rarely show a maximum; pull monthly statements and take the peak. Reasonable estimates are permitted when exact figures aren't available.
When is the FBAR due, and where is it filed?
April 15, with an automatic extension to October 15 — no form needed. It is filed electronically through the Treasury's BSA E-Filing System, separate from the tax return and separate from the IRS. The income tax return's Form 4868 extension does not cover it; the two simply share an October date. Married expats can file one joint FBAR only if all accounts are jointly owned; otherwise each spouse files.
How do FBAR penalties work?
For non-willful failures, a penalty per late report (not per account — the Supreme Court settled that in 2023), inflation-adjusted and currently in the low five figures. For willful failures, the greater of a six-figure amount or half the account balance, per year. In practice, expats who come forward through the Streamlined procedures with a non-willful explanation have penalties waived; expats who file late FBARs with reasonable cause and no unreported income typically receive no penalty. Penalties fall on people who ignore the requirement after learning of it.
Does the FBAR replace Form 8938?
No. Form 8938 is a separate report filed with the tax return, with higher thresholds for people abroad and a broader definition of assets. Many expats file both, listing the same accounts on each.
Frequently asked questions
I live abroad and my only accounts are local. Do I still file an FBAR?
Yes, if their combined peak exceeded $10,000. Living abroad doesn't exempt you; it is the usual reason the FBAR applies.
My account earns no interest and I owe no tax. Still required?
Yes. The FBAR is a disclosure, not a tax form. Tax owed is irrelevant.
My non-U.S. spouse's separate accounts — do I report those?
Not if you have no ownership or signature authority over them. Joint accounts, yes, in full.
I forgot FBARs for several years but filed my returns. What now?
The delinquent FBAR submission procedure covers this when the income was reported; the Streamlined procedures cover it when returns also need fixing.
Next step
Fairlight Accounting handles U.S. domestic, cross-border (U.S.–Canada), and international tax returns, plus bookkeeping, payroll, and CFO advisory. If you're abroad and unsure which accounts belong on your FBAR — or have years to catch up — our U.S. Tax Desk can inventory the accounts and file the right procedure. See pricing or book a free fit call.
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