Tax Q&A in category: International Tax Reporting

Question 1

Does the FBAR $10,000 threshold apply to each account separately or all my accounts combined?

Accepted Answer

Yes. If the aggregate value of all your foreign financial accounts exceeds $10,000 at any point during the calendar year, you must file an FBAR (FinCEN Form 114). The threshold is based on the combined balances across all accounts on any single day, not the year-end balance or any single account.

How the $10,000 threshold works:

Aggregate: Sum the maximum balances of all foreign accounts
Any day test: If the total hits $10,001 even for one day, you file
All accounts: Checking, savings, brokerage, mutual funds, pensions, and some life insurance
Signature authority: Counts even if not your money (business accounts, parents’ accounts)

Account types that count: Account typeReportable on FBARForeign bank accountYesForeign brokerageYesForeign mutual fundYesForeign pension (vested)Yes, in most casesForeign life insurance with cash valueYesSignature authorityYesForeign real estateNo (unless held in an entity) Filing mechanics:

Where: BSA E-Filing System only (separate from Form 1040)
When: Due April 15 with automatic extension to October 15
Dollar reporting: Use year-end Treasury rates to convert maximum balance
Joint accounts: Each holder files unless a spouse signs Form 114a authorization

Penalties for non-filing:

Non-willful: Up to $16,536 per form (inflation-adjusted)
Willful: Greater of $165,353 or 50% of account balance

For FBAR filing help, see our FBAR Reporting Guide.

Question 2

Do I have to report foreign accounts I only have signing authority over on the FBAR?

Accepted Answer

Yes, FBAR rules require you to report any foreign account for which you have a signature or other authority, even if you have no ownership interest. Business operating accounts, employer payroll accounts, parents’ accounts, and charity accounts, where you can sign checks, all trigger FBAR filing once the aggregate exceeds $10,000.

What counts as signature authority:

Sole signatory: You alone can move funds
Joint signatory: You and others can move funds
Check-signing authority: You can sign checks on the account
Wire transfer authority: You can authorize wires
Officers of foreign entities: Automatic if you have a sign-off on accounts

Common signature-authority scenarios: ScenarioReportableOfficer of the employer’s foreign bank accountYesCo-signer on an elderly parent’s foreign accountYesTreasurer of a foreign nonprofitYesTrustee of a foreign trust accountYes Narrow exceptions:

Officers of publicly traded U.S. companies: Limited exemption for SEC-registered entity accounts
Officers of SEC-registered investment companies and their subsidiaries
No exception for private company officers, even if the parent is U.S.

Filing detail:

On FBAR, check the box indicating signature authority, but no financial interest
Still report the maximum balance and account details
Joint owners with spouse: A Special Form 114a election can let one spouse file

For signature authority filing help, see our FBAR Reporting Guide.

Question 3

Do I have to report my Canadian RRSP on the FBAR?

Accepted Answer

Yes, a Canadian Registered Retirement Savings Plan (RRSP) is a reportable foreign financial account on the FBAR. The U.S.-Canada Tax Treaty defers U.S. income tax on RRSP growth until distribution, but that treaty deferral does not remove the FBAR (or Form 8938) reporting obligation.

RRSP FBAR reporting essentials:

FBAR threshold: RRSP balance counts toward the $10,000 aggregate
Maximum value: Report the highest CAD balance, converted to USD at the Treasury year-end rate
Account identification: Name of institution, account number, address
Individual plan: Each spouse files separately on their own RRSP

RRSP on Form 8938 (FATCA):

Included in foreign financial assets
Different thresholds: higher than FBAR, depending on filing status and residence

U.S. tax treatment of RRSP: EventU.S. tax treatmentContributionNo U.S. deduction (treaty prevents double deduction)Growth while workingDeferred under Article XVIIIDistributionTaxable as ordinary income in year receivedCanadian tax withheld on distributionCreditable via FTC on Form 1116 No Form 8891 needed:

Form 8891 was retired in 2014. Treaty deferral is now automatic for RRSPs/RRIFs
FBAR and Form 8938 reporting still required

Watch out for:

Lump-sum distribution treatment under the treaty
Cross-border beneficiary issues if the plan holder dies

For FBAR reporting help, see our FBAR Reporting Guide.

Question 4

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

Accepted Answer

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.

Question 5

Do foreign pensions count toward the FBAR filing threshold?

Accepted Answer

Most foreign pensions count toward the FBAR $10,000 aggregate threshold once they are vested and have an identifiable account value. Defined-contribution pensions (UK SIPP, Australian superannuation, Canadian RRSP) are clearly reportable. Defined-benefit pensions are more nuanced but generally reportable when you have access to or a segregated account.

Pensions commonly reportable on FBAR:

UK SIPP, personal pensions, workplace DC pensions
Australian superannuation (industry, self-managed, retail)
Canadian RRSP, RRIF, LIF, LIRA
French PER, Plan Épargne Retraite
German Riester, Rürup (defined-contribution variants)
Singapore CPF (ordinary and special accounts)
Mexican AFORE

How to report: FieldWhat to enterTypeOther (pension) or securities if brokerage-wrappedMaximum valueHighest balance during the year in USDInstitutionProvider/trustee nameAccount numberPlan or account identifier When a defined-benefit plan is not reportable:

Pure unfunded pension: State pensions with no segregated account generally are not
Promise-only plans with no cash surrender value may not be
Check the provider for an account statement before deciding

Parallel Form 8938 reporting:

Usually reportable on Form 8938 if Form 1040 thresholds met
Do not rely on treaty tax deferral to skip reporting

For pension reporting help, see our Pension Reporting Guide.

Question 6

Does My Child's Foreign Bank Account Need Its Own FBAR Filing?

Accepted Answer

Yes, a U.S. citizen or resident child who has a financial interest in or signature authority over foreign financial accounts with an aggregate value exceeding $10,000 at any point during the year must have an FBAR (FinCEN Form 114) filed in the child’s name. If the child cannot file due to age, a parent, guardian, or other legally responsible person must file on the child’s behalf.

Filed in the child’s name: Use the child’s Social Security Number, not the parent’s
Parent signs electronically: The parent or guardian signs the FBAR for the child
Separate from parents’ FBAR: The child’s FBAR is a distinct filing, not combined with yours
Same $10,000 threshold: Aggregate all of the child’s foreign accounts, including custodial accounts, savings bonds, and education accounts held abroad

Common scenarios for expat families: ScenarioFBAR required for child?The child has a foreign savings account opened by a grandparentYes, if the aggregate is over $10,000Child’s custodial account at a foreign bankYesParent’s account with child listed as beneficiary (not owner)No (child has no financial interest)Joint account with child and parentYes for both parent and child529 plan held at a U.S. institutionNo (U.S. account, not foreign) Does the parent also report the child’s account?

If you have signature authority over your child’s foreign account, that account will also appear on your FBAR. You are not double-counting. The child files (or you file for them) listing ownership, and you file listing signature authority.

Other reporting:

Form 8938: Only required if the child files a Form 1040 and meets the asset threshold
Schedule B: If the child’s return includes interest or dividends, answer the foreign account question

For family FBAR filing help, see our FBAR Reporting Guide.

Question 7

How Does the IRS Find Out About My Foreign Bank Accounts?

Accepted Answer

Under FATCA, your foreign bank identifies you as a U.S. person through due diligence procedures, then reports your account information to its local tax authority (under an Intergovernmental Agreement) or directly to the IRS. The IRS receives your name, address, TIN, account number, year-end balance, and gross interest or dividends paid. Banks that do not comply face a 30% withholding tax on U.S.-source payments.

U.S. indicia screening: Banks search for U.S. birthplace, U.S. address, U.S. phone number, standing transfer instructions to a U.S. account, or a U.S. power of attorney
Self-certification: You may be asked to complete a W-8BEN, W-9, or local equivalent confirming your tax residency
Annual reporting: Banks report once per year, typically covering the prior calendar year
GIIN registration: Each compliant bank receives a Global Intermediary Identification Number, searchable on the IRS FFI list

How the data flows to the IRS: IGA modelHow it worksModel 1 (most countries)Bank reports to the local tax authority, which exchanges with the IRSModel 2 (fewer countries)Bank reports directly to the IRS with local government consentNon-IGABank registers directly with the IRS and reports under its FFI agreement What your bank reports about you: Data elementReportedName, address, U.S. TINYesAccount numberYesYear-end account balanceYesGross interest, dividends, other incomeYesGross proceeds from sales (custodial accounts)Yes Why this matters for your own filings:

The IRS can cross-reference FATCA data against your FBAR and Form 8938. If your bank reports an account that does not appear on your filings, it creates a mismatch flag. Filing both forms accurately and on time is the simplest way to avoid an inquiry.

If your bank asks for documentation you do not recognize, it is likely a FATCA compliance request. Providing the information promptly helps keep your account open.

Question 8

Do I Need to Report My UK SIPP on FBAR, Form 8938, and as a Foreign Trust?

Accepted Answer

Yes, if you are a U.S. citizen living in the UK and you have a UK SIPP account, you may have up to four separate U.S. reporting requirements: the FBAR (FinCEN 114), Form 8938, Form 3520/3520-A for foreign trust treatment, and PFIC reporting for underlying foreign funds. Australian superannuation accounts are subject to the same FBAR and Form 8938 obligations, and self-managed super funds (SMSFs) may also trigger trust reporting.

The IRS generally treats a UK SIPP as a foreign grantor trust because the account holder directs investment decisions. Rev. Proc. 2020-17 exempts certain foreign retirement plans from trust reporting, but SIPPs are widely considered unlikely to qualify because they allow participant-directed investments beyond the scope of that relief. Treaty deferral under Articles 17 and 18 of the U.S.-UK tax treaty may defer income tax on SIPP growth, but it does not eliminate information reporting obligations.

Reporting LayerRequirementThreshold / TriggerFBAR (FinCEN 114)YesAggregate foreign accounts exceed $10,000 at any pointForm 8938Yes$200,000/$400,000 (expat single/MFJ year-end)Form 3520/3520-ALikely yesSIPP treated as foreign grantor trustPFIC (Form 8621)Likely yesSIPP holds foreign mutual funds (OEICs, unit trusts, investment trusts)

If your SIPP holds U.S.-domiciled ETFs or individual stocks rather than foreign funds, the PFIC layer generally does not apply.

If you have been filing your U.S. return without reporting your SIPP, there are catch-up options available. The IRS Streamlined Foreign Offshore Procedures let qualifying expats file three amended returns and six years of FBARs with no penalties if the failure was non-willful. The Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures may also apply depending on your situation.

To know more about how we help Americans living in the UK with UK and U.S. filing requirements in-house at Greenback

Question 9

Do I have to file an FBAR for a foreign account I closed during the year?

Accepted Answer

Yes, if a foreign account you closed during the year contributed to the $10,000 aggregate threshold at any point, you must report it on that year’s FBAR. Report the maximum balance that the account held during the year before closure, along with the account number, institution, and address.

How to report a closed account:

Check the “Account Closed” box on the FBAR account detail
Report the maximum balance reached before closure
Identify the account fully: institution, country, account number
The last year of reporting is the year of closure

When the closure happened: Closure timingReporting effectJanuaryReport once; maximum pre-closure balanceMid-yearReport once; maximum balance during the yearDecember 31Report in the closure year; not required next year What if the closed account is your only foreign account:

Still file if that one account ever exceeded $10,000 in the year
Future years: No FBAR if no other foreign accounts open

Record keeping:

Keep statements for 5 years after filing
Transfer documentation if funds were moved to a U.S. or a different foreign account
Institution closure letter, if available

For FBAR help, see our FBAR Reporting Guide.

Question 10

Do Wise, Revolut, or Other Fintech Accounts Trigger FBAR Reporting?

Accepted Answer

Yes, in most cases. Multi-currency fintech platforms like Wise, Revolut, and N26 hold your funds at financial institutions outside the United States, which makes those balances reportable on the FBAR once your aggregate foreign accounts exceed $10,000 at any point during the year. This catches many expats and digital nomads by surprise because these platforms feel like apps, not foreign bank accounts.

Wise (formerly TransferWise): Non-USD balances are held at partner banks outside the U.S. Your GBP, EUR, or other currency balances are foreign financial accounts for FBAR purposes
Revolut: Depending on your account entity (Revolut Ltd is UK-based, Revolut Lithuania is EU-based), your balances may be held at foreign institutions
N26: German-licensed bank; accounts are foreign financial accounts
PayPal: A U.S. PayPal account is not foreign. A PayPal account registered through a foreign entity (PayPal Europe) may be

How to determine if your fintech account is foreign: Check thisWhat it meansWhere is the entity licensed?If outside the U.S., likely foreignWhere are funds held?If at a non-U.S. bank, foreign for FBARWhat currency is the default?Non-USD default often signals foreign entityWhat does the app’s terms of service say?Look for the regulated entity name and country Reporting details:

Maximum balance: Track the highest combined balance across all currencies in the account during the year, converted to USD
Account number: Use the account identifier shown in the app
Institution: Use the regulated entity name (e.g., “Wise Europe SA” or “Revolut Ltd”)

Other forms these accounts may trigger:

Form 8938 if your total specified foreign financial assets exceed the threshold for your filing status
Schedule B Part III foreign account question

For fintech FBAR questions, see our FBAR Reporting Guide.

Question 11

What Is the Common Reporting Standard (CRS), and How Does It Affect U.S. Expats?

Accepted Answer

The Common Reporting Standard (CRS) is an OECD-developed framework that requires financial institutions in over 100 participating countries to identify account holders’ tax residency and automatically share that data with the account holder’s home tax authority each year. If you are a U.S. citizen living abroad, your foreign bank reports your account information to the local tax authority, which then exchanges it with the IRS through intergovernmental agreements.

Over 100 jurisdictions participate in CRS, including every major expat destination (UK, Canada, Australia, Germany, France, Singapore, UAE)
Banks identify you through self-certification forms (W-8BEN, local equivalents) and due diligence on your nationality, address, and phone number
Data exchanged includes account balances, interest, dividends, gross proceeds, and account holder identity
CRS updated for 2026: the amended CRS now covers electronic money products, central bank digital currencies, and indirect crypto-asset investments

How CRS and FATCA work together: FeatureCRSFATCAWho created itOECDU.S. CongressParticipating countries100+113 IGA partnersDirection of reportingMultilateral (country-to-country)One-way (to the IRS)Who is reportedTax residents of any participating countryU.S. persons specificallyPenalty for banksVaries by local law30% withholding on U.S.-source payments What this means for you as an expat:

Your foreign bank reports your account data to the local tax authority under CRS, and separately to the IRS under FATCA. The IRS now receives your foreign account information from two independent channels. This makes it far more likely that unreported accounts will be detected, which is why filing your FBAR and Form 8938 on time matters more than ever.

Countries that previously had limited IRS data sharing (UAE, Singapore, Hong Kong) now participate in CRS, closing gaps that existed before 2018.

Question 12

Why Do Foreign Banks Refuse to Open Accounts for Americans, and What Can You Do?

Accepted Answer

Many foreign banks refuse to open accounts for U.S. citizens because FATCA requires them to identify U.S. account holders, report their data to the IRS, and face a 30% withholding penalty on U.S.-source payments if they do not comply. For smaller banks, the compliance cost of serving even one American customer can outweigh the revenue from that account.

FATCA compliance burden: Banks must implement due diligence systems to screen for U.S. indicia (birthplace, phone number, address, standing instructions to a U.S. account)
30% withholding risk: Non-compliant banks face 30% withholding on U.S.-source interest, dividends, and certain other payments
Intergovernmental Agreements (IGAs): Most countries signed IGAs requiring local banks to report, but some smaller institutions opt out of serving Americans entirely
Cost-benefit calculation: One U.S. account can cost a bank thousands in annual compliance overhead

Practical steps to open and keep a foreign bank account: StrategyHow it helpsChoose a large international bankMajor banks have a FATCA infrastructure built inBring your SSN and W-9Banks need these to report; having them ready shows complianceProvide proof of local addressDemonstrates genuine local banking needAsk about FATCA-compliant statusConfirm the bank is registered on the IRS FFI list If your bank threatens account closure:

Provide your W-9 and any requested documentation promptly. Banks close accounts when they cannot confirm FATCA status, not because serving Americans is illegal. If your current bank will not cooperate, HSBC Expat, Citibank International, and several digital banks (Wise, Revolut) continue to serve U.S. citizens.

Remember that any foreign account you open triggers FBAR reporting once aggregate balances exceed $10,000, and Form 8938 reporting at higher thresholds.

For more information, see our guide on opening an offshore/foreign bank account.

Question 13

Do I have to report my foreign life insurance on the FBAR?

Accepted Answer

Foreign life insurance policies with a cash surrender value are reportable on both the FBAR and Form 8938 once the applicable thresholds are met. Term-life policies without a cash accumulation feature generally are not reportable because they lack a balance to value.

Policies that are reportable:

Whole life policies with cash surrender value
Universal life policies
Endowment policies
Investment-linked insurance (unit-linked, PPLI, ILAS)
Annuities with foreign insurers

Policies that are generally not reportable:

Term life with no cash value
Group term employer-provided without cash value
Pure protection products with no accumulation

Valuation on the forms: FormValue to useFBARMaximum cash surrender value during the yearForm 8938Maximum cash surrender value during the yearForeign currencyConvert to USD using the Treasury year-end rate Other U.S. tax considerations:

Section 7702 / 7702A: U.S. life insurance rules often not met by foreign policies, causing MEC-like treatment
Section 4371 excise tax: 1% on premiums paid to foreign insurers (reported on Form 720)
PFIC risk if the policy is a wrapper around foreign mutual funds

Question 14

What Is the FBAR Statute of Limitations, and How Long Can the IRS Assess Penalties?

Accepted Answer

The IRS has 6 years from the FBAR due date to assess a civil penalty under 31 U.S.C. § 5321. Because the FBAR for a given calendar year is due April 15 of the following year (with automatic extension to October 15), the six-year window begins on April 15. After the IRS assesses a penalty, it has an additional two years to file a civil action in federal court to collect it.

Six-year assessment period: Runs from the FBAR due date (April 15 of the year after the reporting year)
Two-year collection period: After assessment, the government must file suit within two years under 31 U.S.C. 5321(b)(2)
No tolling for extensions: The automatic October 15 extension does not restart the six-year clock; it runs from the original April 15 due date
Consent to extend: The IRS may ask you to sign Form 872-FA extending the assessment period; you are not required to agree

How this differs from income tax statutes: StatuteFBARIncome tax (Form 1040)Standard assessment period6 years from the due date3 years from filingSubstantial omissionN/A6 yearsFraud or non-filing6 years (same)No limitCollection after assessment2 years (civil action)10 years (administrative) Why unfiled FBARs create extended risk:

The six-year clock starts from the due date of each unfiled FBAR. If you missed the 2020, 2021, 2022, 2023, and 2024 FBARs, each year has its own six-year window. The IRS can assess penalties on the 2020 FBAR until April 2027, the 2021 FBAR until April 2028, and so on. Coming forward through the Streamlined Filing Compliance Procedures or Delinquent FBAR Submission Procedures before the IRS contacts you preserves penalty relief options.

For FBAR penalty questions, see our FBAR Penalties Guide.

Question 15

Do I Need to File an FBAR If I Am a Beneficiary but Not the Owner of a Foreign Account?

Accepted Answer

It depends on whether your beneficiary interest qualifies as a “financial interest” under FinCEN’s FBAR rules. Being named as a beneficiary does not automatically trigger an FBAR filing requirement, but certain beneficiary arrangements do create a financial interest that makes the account reportable.

Under 31 CFR 1010.350, you have a financial interest in a foreign account if:

You own the account directly or hold it jointly
You are the owner of record or holder of legal title, even if acting for someone else
A trust or entity owns the account, and you own more than 50% of the trust’s assets or equity, or you receive more than 50% of the income
A trust grantor who can revoke the trust and reclaim assets has a financial interest in trust-held accounts

Beneficiary ScenarioFBAR Required?Named beneficiary of a foreign trust receiving less than 50% of the incomeGenerally noBeneficiary receiving more than 50% of trust incomeYesRemainder beneficiary with no current distributionsGenerally noGrantor of a revocable foreign trustYesBeneficiary of a foreign pension (employer plan)Depends on plan structureBeneficiary of a deceased person’s account before transferGenerally, no until retitled

If you do have a financial interest, the account value counts toward the $10,000 aggregate FBAR threshold. You may also need to check whether Form 8938 applies at the higher expat reporting thresholds ($200,000/$400,000 single/MFJ year-end).

For trust-held accounts, separate Form 3520 reporting may apply if you received distributions from a foreign trust during the year.

Question 16

What happens if the IRS finds a foreign account I did not report on FBAR?

Accepted Answer

If the IRS discovers a foreign account you failed to report on the FBAR before you come forward, you lose eligibility for the Streamlined or Delinquent FBAR Submission Procedures. Penalties can reach $16,536 per form for non-willful violations or the greater of $165,353 or 50% of the account balance per year for willful violations, inflation-adjusted.

How the IRS typically finds unreported accounts:

FATCA reports: Foreign banks submit account data for U.S. persons
Treaty exchange: Multilateral information exchange under TIEAs and CRS
Whistleblowers: Former employees, ex-spouses, disgruntled advisors
Audit: A domestic audit uncovers a wire transfer abroad
Form 8938 vs FBAR mismatch: Discrepancy flags for review

Penalty structure: ViolationCivil penaltyNon-willfulUp to $16,536 per form, per yearWillfulGreater of $165,353 or 50% of account balance per yearCriminal willfulUp to $500,000 and/or 10 years imprisonment Defenses available:

Non-willful factual showing (negligence, mistake, misunderstanding)
Reasonable cause statement based on specific facts
Mitigation guidelines: IRS may reduce penalties in modest cases
Reliance on professional advice: When properly documented

If you have unreported accounts:

Come forward before IRS contact: Preserves Streamlined eligibility
Do not delay: Statute of limitations extends while non-compliant
Get professional help before any disclosure

For catch-up options, see our Streamlined Filing Compliance Procedures.

Question 17

How Do I Calculate the Maximum Account Value for My FBAR?

Accepted Answer

For each foreign account on your FBAR (FinCEN Form 114), you must report the highest balance the account held at any point during the calendar year, converted to U.S. dollars using the Treasury Reporting Rates of Exchange for December 31 of that year. This is not the year-end balance; it is the peak balance, even if the account was at zero by December 31.

Check every statement period (monthly or quarterly) and use the single highest closing balance
Convert using the Treasury year-end rate, not your bank’s rate or an online converter
Round up to the next whole U.S. dollar
If no Treasury rate exists for your currency, use another verifiable exchange rate and note the source

Account TypeHow to Determine Maximum ValueChecking/savingsHighest statement balance during the yearBrokerageHighest periodic statement value (including securities at market value)Foreign pensionYear-end statement value if no interim statements are availableTerm deposit/CDPrincipal plus accrued interest if no early withdrawal is possibleJointly heldReport the full account value (not your proportional share) Common mistakes:

Using the year-end balance instead of the peak balance
Using the IRS yearly average rate (that rate is for income conversion on Form 1040, not for FBAR)
Forgetting to include accrued interest on fixed deposits
Excluding accounts that were closed mid-year (report the peak value before closure)

The $10,000 aggregate threshold also uses maximum values. Add the peak value of every foreign account on the same day to determine whether you exceed $10,000 on any single day during the year.

For more on FBAR filing, see our FBAR Reporting Guide.

Question 18

What is the FATCA reporting threshold for married couples filing jointly and living abroad?

Accepted Answer

U.S. taxpayers filing married filing jointly and living abroad must file Form 8938 if their specified foreign financial assets exceed $400,000 on the last day of the tax year, or $600,000 at any point during the year. These are the highest Form 8938 thresholds and apply only when both spouses qualify as living abroad.

What counts as living abroad for Form 8938:

Tax home in a foreign country, and
Bona fide resident of a foreign country for an uninterrupted tax year, or
Physical presence in a foreign country for at least 330 full days in a 12-month period ending in the tax year

All Form 8938 thresholds: Filing statusLiving abroadLiving in the U.S.Single / MFS$200k year-end or $300k peak$50k year-end or $75k peakMFJ$400k year-end or $600k peak$100k year-end or $150k peak Specified foreign financial assets include:

Foreign financial accounts (bank, brokerage, pension)
Directly held foreign stock and securities
Foreign partnership interests
Foreign-issued insurance with cash value
Foreign trust and estate beneficial interests

Consolidated reporting:

One Form 8938 covers both spouses on the MFJ return
Joint and individual accounts are all included
Consistency with FBAR is strongly recommended

Penalty structure:

$10,000 initial, plus $10,000 per 30-day period after IRS notice, up to $50,000
40% accuracy-related penalty on tax attributable to undisclosed specified foreign assets

For FATCA help for joint filers, see our Form 8938 guide.

Question 19

Does my FBAR extension need to be separately requested, or does it apply automatically?

Accepted Answer

The FBAR (FinCEN 114) for the 2025 tax year is due April 15, 2026, with an automatic extension to October 15, 2026. You do not need to file a separate request for the extension; it is applied automatically by FinCEN.

Key deadline details:

Original due date: April 15, 2026
Automatic extension: October 15, 2026
No Form 4868 needed: The FBAR extension is automatic
Expat residency does not change the FBAR deadline

What if October 15 falls on a weekend or holiday:

Deadline moves to the next business day
Still files through the BSA E-Filing System

Related filings and 2026 deadlines: FilingDeadlineForm 1040 originalApril 15, 2026Form 1040 automatic expat extensionJune 15, 2026Form 1040 with Form 4868October 15, 2026Form 8938With Form 1040FBARApril 15, 2026 (auto-ext to October 15, 2026) Late FBAR options:

Reasonable cause statement with a timely-filed FBAR for a prior year
Delinquent FBAR Submission Procedures for prior years never filed
Streamlined Foreign Offshore if tax issues also exist

For catch-up FBAR filing help, see our FBAR Reporting Guide.

Question 20

What is the penalty for accidentally forgetting to file an FBAR?

Accepted Answer

Accidental or non-willful FBAR non-filing carries a civil penalty of up to $16,536 per form, per year (inflation-adjusted from the $10,000 statutory amount). The Streamlined Filing Compliance Procedures and the Delinquent FBAR Submission Procedures both waive this penalty for non-willful filers who act before the IRS contacts them.

Non-willful FBAR penalty range:

Per form, per year: up to $16,536 (inflation-adjusted)
Per account (Bittner v. United States): Only one per-form penalty per year, regardless of the number of accounts
Mitigation guidelines: IRS often reduces significantly in modest cases

Willful FBAR penalty (for contrast):

Greater of $165,353 or 50% of the account balance per year
Up to $500,000 and/or 10 years imprisonment for criminal willful

How to fix accidental non-filing:

Streamlined Foreign Offshore: 3 years of tax returns and 6 years of FBARs, non-willfulness certification
Delinquent FBAR Submission Procedures: FBAR-only fix when all income was reported and no tax is owed
Both options require you to act before the IRS contacts you

Documentation to keep: DocumentWhyBank statementsSupport maximum balanceNon-willfulness factsSupport your certificationPrior filing attemptsHelp show good faithTax return copiesVerify income was reported

For accidental non-filing help, see our Streamlined Filing Compliance Procedures.

Question 21

What foreign financial accounts do I have to declare on my U.S. tax return?

Accepted Answer

U.S. taxpayers with foreign financial accounts must disclose them in several places. Schedule B Part III asks whether you have any foreign accounts. The FBAR (FinCEN 114) must be filed separately if the aggregate balances exceed $10,000. Form 8938 is attached to Form 1040 if specified foreign assets exceed your threshold.

Where foreign accounts show up on your return:

Schedule B Part III: Yes/No foreign account question plus country list
Form 8938: Attached to 1040 if threshold met
Form 1040 digital asset question: Yes/No about crypto
Form 1116: If claiming FTC on foreign-source income
FBAR: Separately via BSA E-Filing

Accounts typically reported: AccountSchedule BFBARForm 8938Foreign bankYesYes over $10kYes over thresholdForeign brokerageYesYes over $10kYes over thresholdForeign pensionYesYes over $10kYes over thresholdForeign life insurance (cash value)YesYes over $10kYes over thresholdSignature onlyYesYesNoForeign stock (direct, not in account)NoNoYes over threshold Schedule B question nuances:

Answer ‘Yes‘ even if FBAR is not required
Name each country where you have an account
Answer ‘Yes‘ if you have signature authority

For account disclosure help, see our FBAR Reporting Guide.

Question 22

My Foreign Bank Sent Me a FATCA Letter Asking If I Am a U.S. Person. What Do I Do?

Accepted Answer

Respond promptly and honestly. Under FATCA, foreign financial institutions (FFIs) are required to identify U.S. account holders and report their account information to the IRS. When your bank sends a self-certification or “FATCA letter,” it is asking you to confirm whether you are a U.S. person for tax purposes. If you are a U.S. citizen or green card holder, the answer is yes, regardless of where you live.

Complete the Form W-9 (or your bank’s local equivalent) confirming your U.S. tax status
Do not submit a W-8BEN if you are a U.S. citizen or resident alien; that form certifies foreign status, and submitting it falsely is a federal offense
Respond by the bank’s deadline; ignoring the request is the most common reason banks close American clients’ accounts
Your bank will report your account details (name, address, TIN, balances) to the IRS annually via FATCA intergovernmental agreements

What the bank asksWhat you provideWhyFATCA self-certification formCheck “U.S. person” and signConfirms your status under local FATCA rulesIRS Form W-9Complete with name, address, and SSNStandard U.S. person identificationTax Identification Number (TIN)Your Social Security NumberRequired for FATCA reporting to the IRSProof of U.S. statusU.S. passport or green card copySome banks request supporting documentation

Providing your information does not create any new tax obligation. It simply means the bank reports your account to the IRS, which the IRS may already know about through other channels. You are still independently responsible for filing your FBAR and Form 8938 if your accounts meet the reporting thresholds.

If your bank will not serve U.S. clients, alternatives include HSBC Expat, Citibank International, and digital banks like Wise and Revolut that continue to accept U.S. persons.

Question 23

Does an overseas mortgage or property account count as a foreign financial account for FBAR reporting?

Accepted Answer

An overseas mortgage loan account itself is generally not FBAR-reportable because it represents a debt you owe, not a financial asset you own. However, any escrow or offset account held at a foreign financial institution with funds in your name is reportable on the FBAR if the aggregate $10,000 threshold is met.

Mortgage-related accounts and FBAR:

Loan account (debt you owe): Not reportable
Escrow account (your funds held by lender): Reportable
Offset account (your cash reducing mortgage interest): Reportable (common in Australia, NZ, UK)
Mortgage current account (savings linked to loan): Reportable

Other property-linked accounts: Account typeFBAR reportableForeign real estate (direct ownership)NoRental income account (at foreign bank)YesHOA/Strata reserve account you controlOftenForeign property held by an entity you controlEntity files; you may have signature authority What about the property itself:

Direct real estate is not on FBAR
Form 8938 requires reporting when held through certain foreign entities
Schedule E reports rental income on your return

Offset accounts specifically:

Common in Australia, NZ, UK
Functionally, a savings account linked to the mortgage
Reportable at the maximum balance during the year

For FBAR questions, see our FBAR Reporting Guide.

Question 24

Does a foreign cryptocurrency exchange account require FBAR reporting for U.S. expats?

Accepted Answer

FinCEN Notice 2020-2 indicates that foreign cryptocurrency exchange accounts will be subject to FBAR reporting once the final rule is issued. While the regulation is not yet finalized, most tax practitioners recommend that U.S. expats report foreign-custodied crypto accounts on the FBAR now. Expats face additional complexity because living abroad often means your primary exchange is a foreign platform, creating FATCA and Form 8938 obligations in addition to the FBAR question.

Conservative FBAR filing: Report any account on a foreign centralized exchange (Binance non-U.S., Bitstamp, Kraken EU, Crypto.com Singapore, OKX) as a foreign financial account
Self-custody wallets: Hardware wallets and software wallets you control are not held at a financial institution, so they are likely outside the FBAR scope
DeFi protocols: No custodian holds your funds, so FBAR likely does not apply, but guidance is still evolving
Hybrid platforms: Some exchanges also offer staking, lending, or savings products that create additional taxable events

Why expats face extra crypto reporting layers: ObligationTrigger for expatsFBAR (conservative)Any foreign exchange account contributing to a $10,000 aggregateForm 8938Foreign financial assets over $200,000 (single) or $400,000 (MFJ) at year-end for expats abroadForm 1040 digital asset questionAny crypto transaction during the yearSchedule D / Form 8949Sales, swaps, or disposalsHost-country reportingMany countries (UK, Australia, Germany) now require separate crypto disclosure Expat-specific considerations:

Local exchange regulations vary. Some countries (Japan, South Korea) require identity verification that ties your account to a local address, making the account clearly foreign for FBAR purposes. Others (UAE, Portugal) have lighter reporting, but do not change your U.S. obligations.

If you used a U.S.-based exchange before moving abroad and kept the account open, that account is not considered a foreign account for FBAR purposes, even if you access it from overseas. Only accounts maintained by a non-U.S. entity qualify.

For crypto reporting help, see our Cryptocurrency Tax Guide.

Question 25

Do I have to report gold on my FBAR?

Accepted Answer

A foreign-held gold account in custody at a foreign financial institution (such as an allocated or unallocated bullion account) is FBAR-reportable. Physical gold you store in a foreign safe deposit box or hold personally abroad is generally not reportable. Form 8938 may cover foreign-issued gold securities and certain unhosted positions.

FBAR treatment:

Custodial bullion account: Reportable (Perth Mint, Swiss bank, etc.)
Allocated gold held via foreign provider: Reportable
Unallocated pooled metal accounts: Reportable
Safe deposit box holding coins/bars: Not reportable
Home storage abroad: Not reportable

Form 8938 treatment: AssetForm 8938Custodial gold accountYes (financial account)Foreign-issued gold ETFYes (likely a PFIC too)Gold mining stock (foreign)YesPhysical bullion at home abroadNo Related income reporting:

Sales or exchanges of gold on Form 8949 / Schedule D
Collectibles capital gains rate (up to 28%)
Foreign tax paid on gold sale is creditable

Planning note:

Home-storage bullion has no reporting, but also no step-up on death planning advantages
Custodial accounts simplify reporting and valuation, but trigger FBAR

For FBAR reporting help, see our FBAR Reporting Guide.

Question 26

Do I have to report a custodial account on Form 8938?

Accepted Answer

Yes, a custodial account is a financial account where a bank, broker, or other institution holds assets (stocks, bonds, mutual funds, or cash) on your behalf. You own the assets inside the account, but the institution is the legal custodian that safeguards them, executes trades, and issues statements. If the custodial account is held at a foreign financial institution and your total specified foreign financial assets exceed the Form 8938 thresholds, you must report it.

Common examples of foreign custodial accounts:

Foreign brokerage accounts (e.g., Hargreaves Lansdown, Interactive Brokers UK, Saxo Bank)
ISAs (Individual Savings Accounts) in the UK are held by a custodian
Foreign nominee accounts where a bank holds shares in its name on your behalf
Managed investment accounts at a foreign wealth manager
Foreign mutual fund platforms that custody your fund units

Reporting thresholds for expats living abroad: Filing StatusYear-End ValuePeak Value Any TimeSingle / MFS$200,000$300,000Married Filing Jointly$400,000$600,000

A foreign custodial account is also reportable on your FBAR if your aggregate foreign account balances exceed $10,000 at any point during the year. The FBAR threshold is much lower and applies regardless of filing status.

What is NOT a custodial account:

Directly registered shares where you appear on the company’s shareholder register (still reportable on Form 8938, but as an “other specified foreign financial asset,” not as an account)
A UGMA/UTMA account you set up for a minor at a U.S. institution (U.S. accounts are not reportable)
Physical assets like real estate, art, or gold bullion held in a vault (not reportable on Form 8938)

For more on FATCA thresholds, see our Form 8938 guide.

Question 27

Do Green Card Holders Still Have to File an FBAR After Moving Back to Their Home Country?

Accepted Answer

Yes, a lawful permanent resident (green card holder) is a “U.S. person” for FBAR purposes and must file FinCEN Form 114 if aggregate foreign financial accounts exceed $10,000 at any point during the year. This obligation continues until you formally abandon or surrender your green card. Simply moving back to your home country does not end the requirement. The IRS treats you as a U.S. person with worldwide filing obligations until your residency is officially terminated.

FBAR obligation continues as long as your green card is valid or not formally surrendered
Filing Form I-407 (Record of Abandonment of Lawful Permanent Resident Status) with USCIS formally ends your green card and your status as a U.S. person
Treaty tiebreaker claims do not end FBAR: even if you claim nonresident status under a tax treaty for income tax purposes, FinCEN does not recognize treaty overrides for FBAR
Long-term residents (8+ years with a green card) may face an exit tax under IRC 877A upon surrender

When your FBAR obligation ends: EventFBAR effectMove abroad but keep a green cardStill requiredClaim treaty-based nonresident status on Form 1040-NRStill required (FBAR follows FinCEN rules, not treaty)File Form I-407 abandoning green cardObligation ends the year after abandonmentGreen card administratively revoked by USCISObligation ends upon revocationNaturalize as a U.S. citizenObligation continues (now as a citizen) Common traps:

Living abroad without filing creates a dual risk. USCIS may view extended absence as evidence that you abandoned residency (jeopardizing immigration status), while the IRS may assess FBAR penalties for non-filing during the same period. Filing protects you on both fronts.

If you have unfiled FBARs from years you lived abroad while holding a green card, the Streamlined Filing Compliance Procedures or Delinquent FBAR Submission Procedures can help you catch up.

Question 28

Can I amend my FBAR if I made a mistake or left out information?

Accepted Answer

Yes, if you made a mistake or omitted an account on your original FBAR, file an amended FBAR through the BSA E-Filing System. Mark the form as amended, enter the original BSA identifier, and include a brief explanation in the amended filing explanation box.

When to amend an FBAR:

Missing account discovered after filing
Wrong maximum balance reported
Wrong account number or institution name
Signature authority accounts are overlooked
Joint account not listed on one spouse’s FBAR

How to amend:

Log in to the BSA E-Filing System
Start a new FBAR marked as amended
Enter the BSA ID number of the prior filing
Provide a short explanation of what changed
Re-enter all accounts (amended FBAR replaces the original)

Amendment timing: SituationBest pathFound a minor error within 1 yearAmend directlyMissed multiple years of accountsConsider Delinquent FBAR Submission ProceduresSignificant tax implicationsStreamlined or VDP evaluationIRS already inquiringConsult tax counsel immediately Amendment vs program submission:

An amendment is appropriate for corrections to already-timely-filed FBARs
Delinquent FBAR Submission is for prior-year FBARs never been filed
Streamlined is for FBAR plus income tax deficiencies

For FBAR help, see our FBAR Reporting Guide.

Question 29

Are My Foreign Brokerage Accounts Reported on the FBAR?

Accepted Answer

Both foreign bank and foreign brokerage accounts are reportable on the FBAR. Reporting is largely identical: identify the institution, country, account number, and the maximum value during the year converted to USD. The type selector on the FBAR distinguishes between “Bank” and “Securities” accounts, but both count toward the $10,000 aggregate.

Similarities:

Both count toward the $10,000 aggregate threshold
Both report the maximum value during the year
Both require the institution name, address, and account number

Differences in reporting: FeatureBank accountBrokerage accountType on FBARBankSecuritiesValue basisCash balanceMarket value of holdings plus cashSeparate fundsNoUnderlying foreign funds may be PFICs Related filings, brokerage accounts often trigger:

Form 8938 (if 1040 thresholds met)
Form 8621 per PFIC held inside the account
Schedule B foreign account question
Schedule D / Form 8949 for sales

Reporting tip:

The maximum value for a brokerage account is typically a month-end statement figure, but use the highest observed during the year if known
Convert from foreign currency using the Treasury year-end exchange rate

For FBAR filing help, see our FBAR Reporting Guide.