What Is the FBAR? Reporting Foreign Bank Accounts
Who files, the US$10,000 aggregate test, which Canadian accounts count, and the penalties
Reviewed by the Fairlight Accounting cross-border tax team — U.S. & Canadian Tax Desks
The FBAR — FinCEN Form 114 — is filed by every U.S. person whose foreign financial accounts total more than US$10,000 at any time in the year. It goes to the Treasury's Financial Crimes Enforcement Network, not the IRS, and reports accounts rather than income. Canadian bank, investment, RRSP, and TFSA accounts all count.
On this page
Who files and what counts
| Item | Rule |
|---|---|
| Who | U.S. citizens, green card holders, U.S. residents (substantial presence), and U.S. entities — wherever they live |
| Threshold | Aggregate maximum value of all foreign accounts above US$10,000 at any point in the year |
| Accounts | Bank accounts, brokerage and investment accounts, RRSPs, RRIFs, TFSAs, RESPs, cash-value life insurance and annuities, and foreign pension and retirement accounts (the FBAR exemption covers only IRAs and U.S. tax-qualified plans) |
| Interest | Accounts you own, jointly own, or have signature authority over (including an employer's or a parent's account) |
| Value | Each account's highest balance in the year, converted at the Treasury's year-end rate |
When and how
Due April 15, with an automatic extension to October 15 — no request needed. Filed online through the BSA E-Filing System, separately from the tax return. Form 8938 is a separate IRS filing with higher thresholds (the Form 8938 guide); many people file both.
Penalties
Non-willful violations: up to US$16,536 per report for penalties assessed in 2026 — the Supreme Court held in Bittner v. United States (2023) that the non-willful penalty applies per report, not per account. Willful violations: the greater of US$165,353 or 50 percent of the account balance at the time of the violation. Both are FinCEN's 2025 inflation-adjusted maximums, which still apply in 2026 because no 2026 adjustment was made. Late filers with no unreported income file the missing FBARs through BSA E-Filing with an explanation of why they're late — the IRS no longer publishes its former delinquent FBAR submission procedures, so there is no published no-penalty assurance; those with unreported income use the streamlined procedures (the streamlined guide).
Frequently asked questions
Do I need to file an FBAR for my Canadian bank account?
Yes, if you're a U.S. person and all your foreign accounts together exceeded US$10,000 at any time during the year.
Do RRSPs and TFSAs go on the FBAR?
Yes — both are foreign financial accounts for FBAR purposes.
When is the FBAR due?
April 15, automatically extended to October 15.
What if I never filed FBARs?
With no unreported income, file the missing FBARs through BSA E-Filing with an explanation of why they're late — the IRS no longer publishes its former separate delinquent FBAR submission procedures. With unreported income, the streamlined procedures are the usual path.
Official sources
FinCEN explains: “A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.” — Financial Crimes Enforcement Network, Report Foreign Bank and Financial Accounts, https://www.fincen.gov/report-foreign-bank-and-financial-accounts
Next step
Fairlight Accounting is a cross-border accounting and tax practice with a U.S. Tax Desk and a Canadian Tax Desk. Our U.S. Tax Desk and Canadian Tax Desk handle FBAR preparation and delinquent FBAR submissions for U.S. persons with Canadian accounts. See pricing or book a call.
Cross-border taxes, handled in one place
U.S. and Canadian filings prepared together by our U.S. and Canadian Tax Desks.
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