FBAR for US Expats: What to File, When It’s Required, and How to Stay Organized

If you’re an American living abroad, you may be required to file an FBAR (Foreign Bank Account Report) each year — even if you owe no US tax at all.

This catches people off guard.

The FBAR isn’t about tax. It’s about disclosure. And for expats juggling accounts across countries, platforms, currencies, and years, compliance often breaks down due to poor tracking, not bad intent.

This guide explains when FBAR filing is required, what counts as a foreign account, and how to stay ahead of it without last-minute chaos.

What Is an FBAR?

The FBAR, officially FinCEN Form 114, is an annual disclosure required under the Bank Secrecy Act. It exists to give the US Treasury visibility into foreign financial accounts held by US persons.

It is:

• Filed electronically
• Separate from your tax return
• Submitted to FinCEN, not the IRS

The FBAR reports where your money is held, not whether it’s taxable.

That distinction matters.

Who Must File an FBAR?

You must file if all three apply:

1. You’re a US citizen, Green Card holder, or US person
2. You have a financial interest in or signature authority over foreign accounts
3. The combined maximum value of those accounts exceeded $10,000 at any time during the year

The $10,000 threshold is aggregate, not per account.

Why “Maximum Balance” Trips People Up

FBAR rules look at the highest balance each account reached, not how much you held overall at one moment.

Example:
You move the same $6,000 between two foreign accounts during the year.
Each account’s peak balance was $6,000.
Combined max = $12,000 → FBAR required

This is one of the most common sources of accidental non-compliance.

Financial Interest vs. Signature Authority

You may need to report accounts even if you don’t own them.

• Financial interest: You own or control the funds (directly or indirectly)
• Signature authority: You can move or manage funds without owning them

Example:
A parent with access to a child’s foreign savings account
An employee authorized on a company account
An adult assisting elderly parents

If your total access exceeds $10,000, filing is required.

Currency Conversion Rules

All balances must be reported in US dollars, using the Treasury’s official year-end exchange rate.

Key rule:
Use one consistent exchange rate across all accounts for the year.

Accounts That Typically Must Be Reported

• Foreign checking and savings accounts
• Brokerage and investment accounts
• Foreign pensions or retirement plans
• Life insurance policies with cash value

Income doesn’t matter. Balance does.

FBAR Deadlines (and Extensions)

• Standard deadline: April 15
• Automatic extension: October 15

No action is required to receive the extension.

This extension applies only to the FBAR — not your tax return.

Online Wallets and Payment Platforms

Whether an online account counts depends on regulation, not brand recognition.

Platforms like Wise, Revolut, or PayPal may count as foreign accounts if:

• The account is opened abroad, or
• The account is regulated by a non-US authority

If it’s held under US regulation, it generally does not count.

Spouses and Children

FBAR filing is individual, not household-based.

• Each US person with qualifying accounts must file
• Children with foreign accounts may require an FBAR filed on their behalf
• Parents with access to a child’s account must include it in their own totals

Spouses can file jointly only if all accounts are jointly owned and both sign the FBAR declaration.

How to File an FBAR

FBARs are filed electronically via FinCEN’s BSA E-Filing System.

Before filing, you’ll need:

• Maximum annual balance (USD)
• Account number
• Financial institution name and address
• Account type

Once submitted, you’ll receive a confirmation record.

FBAR vs FATCA (Form 8938)

These are often confused. They’re not interchangeable.

Many expats must file both.

FBAR Penalties: What Changed Recently

The IRS distinguishes between non-willful and willful violations.

Non-Willful

• Up to $10,000 per year
• Often waived if corrected voluntarily

Willful

• Greater of $100,000 or 50% of account balance
• Per account, per year
• Potential criminal exposure

Important 2023 Update

In Bittner v. United States, the Supreme Court ruled that non-willful penalties apply per form, not per account — significantly reducing exposure for honest mistakes.

Still, prevention beats cleanup.

Missed FBARs? You Still Have Options

Delinquent FBAR Submission

For those who filed tax returns but missed FBARs.

Streamlined Filing Compliance

For those who missed both tax returns and FBARs, assuming non-willful behavior.

Critical rule:
You must act before the IRS contacts you.

Once they do, penalty relief options disappear.

Why FBAR Compliance Breaks Down

FBAR failures rarely come from intentional hiding.

They come from:

• Fragmented accounts
• Lost balance history
• Inconsistent recordkeeping
• Relying on memory instead of systems

This is an organization problem masquerading as a tax problem.

Stay FBAR-Ready With NomadLedger

NomadLedger is built for US expats and digital nomads who want:

• A single source of truth for foreign accounts
• Year-by-year balance tracking
• Clean records when filing or catching up
• Fewer compliance surprises

FBAR filing becomes easy when the data already exists.