Your foreign accounts passed $10,000 together, even for one day. That is an FBAR.

Lands on FinCEN Form 114, filed online — no line of the tax return, though Schedule B asks about the accounts

If every account you hold is in the United States, this article is not for you — and that includes a U.S. brokerage account that buys foreign shares for you, which the IRS does not treat as a foreign account. It is also not about which exchange rate to use: that has its own article. And it does not cover the rules for companies reporting 25 or more accounts, or for employees who sign on their employer's accounts.

It is for the freelancer paid into a bank or payment account abroad, the American living overseas, and anyone who keeps money in a foreign account and has just learned that there is a report for it.

The short answer

"U.S. person" is wider than it sounds. It covers citizens and residents, and also companies, partnerships, trusts and estates formed in the United States. A single-member company that the tax rules ignore may still have to file its own: FBARs "are required under a Bank Secrecy Act provision of Title 31, not under any provision of Title 26."

The $10,000 is every account, added up

The test is not whether any one account reached $10,000. It is whether "the aggregate value of those foreign financial accounts exceeded $10,000 at any time during the calendar year reported." Each account counts at its highest value in the year, and the highest values are added together, even if they were reached in different months.

Two examples in Publication 5569 show both halves of the rule. Accounts with balances of $3,000, $1,000 and $8,000 must all be reported, "It doesn't matter that no single account exceeded $10,000." And once the total passes the line, every account goes on the form, however small: someone with accounts at $100, $12,000 and $3,000 "must report foreign financial accounts X, Y, and Z on the FBAR even though accounts X and Z have maximum account values below $10,000."

The highest value is "a reasonable approximation of the greatest value of currency and non-monetary assets in the account during the calendar year," and statements issued at least quarterly may be used if they fairly reflect it. Each account's highest value is found in its own currency first, then converted at the Treasury's rate for the last day of the year, a different rate from the one used for income. The exchange rate article works through the difference.

Whether the account earned anything does not matter. Publication 5569: "Whether or not an account produces income doesn't affect the requirement to file an FBAR."

What counts as a foreign account

The IRS names the common kinds as "bank accounts, brokerage accounts and mutual funds." Where the account is held decides whether it is foreign, not who owns the bank. The examples:

• An account at a branch of a U.S. bank in Germany is a foreign account.
• An account at a branch of a French bank in Texas is not.
• French shares bought through a broker in New York are not, because the account is in the United States.

Some accounts are left out. Among them are accounts held by an IRA you own or benefit from, accounts held by a retirement plan you take part in, and accounts at a U.S. military banking facility, even one outside the country. An account holding only cryptocurrency is not reportable at present, though Publication 5569 notes that FinCEN intends to propose changing that.

Signature authority counts on its own

You do not have to own the money. Authority "to control the disposition of assets held in a foreign financial account by direct communication" to the bank is enough. The IRS's example is a daughter holding a power of attorney over her parents' accounts in Canada that she has never used. She must file if it gives her signature authority, because "Whether or not Megan ever exercised the authority is irrelevant to the FBAR filing requirement."

A joint account is reported in full by each owner. Spouses have one exception. One spouse need not file separately when every account they must report is held jointly with the filing spouse, the filing spouse reports those accounts on a timely FBAR, and both have signed FinCEN Form 114a, which is kept with the records rather than sent.

Filing it: online, and not with your return

"You must file the FBAR electronically through FinCEN's BSA E-Filing System. You don't file the FBAR with your federal tax return." Paper is possible only with an exemption granted by FinCEN, and a printed Form 114 is not accepted. If someone else, such as a preparer, files for you, you authorize them on FinCEN Report 114a and keep it; it is not sent in. Each filing is acknowledged.

The tax return still asks about the accounts. Publication 5569 lists the FBAR-related questions on returns, among them Form 1040, Schedule B, questions 7a and 7b. Answering them does not file the FBAR, and filing the FBAR does not answer them.

The dates

The FBAR is due April 15 after the year it reports. Anyone who misses that date has "an automatic extension to October 15," and "You don't need to request an extension to file the FBAR." For accounts held during 2025, October 15, 2026 is the last automatic date. A disaster notice can move it later for those affected.

If some figures are still missing in October, Publication 5569's advice is to "file as complete an FBAR as possible and amend it when more or new information becomes available."

A year you missed

A late FBAR is filed through the same system, which accepts past calendar years, and the form has a box to explain the late filing. The IRS's direction is plain: if it has not contacted you about a late FBAR and you are not under investigation, "you should file late FBARs as soon as possible to keep potential penalties to a minimum." Where the accounts are properly reported and the IRS finds the delay had reasonable cause, "no penalty will be imposed." Taxpayers using a compliance program, such as the Streamlined filing compliance procedures, follow that program's instructions instead.

The penalties are serious enough not to guess at. Civil penalties "have varying upper limits, but no minimum," and the upper limits are adjusted for inflation every year, so the IRS's own materials warn that the figures in them "may not be current." A willful failure can cost up to the greater of the adjusted limit or "50% of the amount in the account at the time of the violation," and criminal penalties can apply as well.

Form 8938 is a different filing

Form 8938 also reports foreign assets, and it is filed with the tax return. It does not replace the FBAR: it "does not replace or otherwise affect a taxpayer's obligation to file FinCEN Form 114." Its thresholds are much higher:

Someone living in the United States with $15,000 in a foreign bank account may owe an FBAR and no Form 8938.

What to keep

For each account on the FBAR, keep the name on the account, the account number, the bank's name and address, the type of account and its highest value in the year, for five years from the FBAR's due date. The law does not prescribe the document. Bank statements do, and so does a copy of the filed FBAR if it holds the same information. For a freelancer, where each platform holds your money is the first thing to write down, and working abroad has its own separate rules for the income.

Common questions

This article is for educational purposes only and does not constitute tax, legal, or financial advice. Consult a qualified tax professional about your situation.

Official sources

• IRS: Report of Foreign Bank and Financial Accounts (FBAR)
• IRS Publication 5569 — FBAR Reference Guide
• IRS: Comparison of Form 8938 and FBAR requirements