Do I owe an FBAR if I have no U.S. income tax filing requirement this year?

Yes. FBAR filing is independent of your U.S. income tax filing obligation. If your aggregate foreign financial accounts exceeded $10,000 on any day during the year, you must file FinCEN Form 114, even if your income is below the Form 1040 filing threshold.

Why FBAR and 1040 are separate:

• Different agencies: FBAR is a Treasury/FinCEN filing; 1040 is an IRS filing
• Different purposes: FBAR is anti-money-laundering disclosure; 1040 is income tax
• Different thresholds: FBAR is $10,000 aggregate account balance; 1040 is income-based

Who still owes FBAR even with a low income:

• Retirees abroad with foreign pensions holding modest balances that cross $10,000 at some point
• Students abroad with a foreign savings account
• Gig workers with small earnings but larger savings
• Stay-at-home spouses with signature authority on joint accounts

What you do not file if you have no 1040 requirement:

• No Form 1040 if below the filing threshold, and nothing else triggers a return
• No Form 8938 (tied to 1040 attachment)
• Still file FBAR if over $10,000 aggregate

Filing tips:

• BSA E-Filing: Free, direct, no accountant required
• October 15 automatic extension
• Six-year look-back if catching up via Delinquent FBAR Submission

For FBAR help, see our FBAR Reporting Guide.