Compliance
Foreign Account Records: A Checklist for Your Tax Preparer
Missing statements, an unfinished organizer, or unlabeled uploads do not stop an FBAR. Rebuild the account map year by year, then document what is missing.
A tax conversation becomes harder when one number is a CD principal, another is a savings-account peak, and a third is a balance in Canadian dollars. The arithmetic may be correct while the total answers the wrong question.
A good handoff makes each amount identifiable before anyone adds it up. This checklist is designed for someone with foreign savings, time deposits, or accounts in more than one country.
Start with one row per possible account
Use a working name such as “Savings A” or “Deposit B.” In your private records, connect that alias to the actual institution and account documents. Mark uncertain account structures for review.
| Field | What to record |
|---|---|
| Reporting year | The calendar or tax year under review |
| Institution and country | Where the account is maintained |
| Ownership | Sole, joint, signature authority, or another relationship |
| Product | Savings, time deposit, brokerage, or the contract's description |
| Currency | USD, CAD, or the actual account currency |
| Dates | Opening, closure, renewal, or institution transfer |
| Supported maximum | Amount, date or period, and source record |
| Year-end value | Amount and year-end statement |
| Income | Interest or other income, tracked separately |
| Filing history | FBAR, return attachments, and acknowledgment records |
This is a preparation worksheet. It does not decide which rows become separate reportable accounts. For that issue, read which identifier to use for a foreign CD.
Keep maximum and year-end values apart
Imagine Savings A reached USD 18,000 in April and ended the year at USD 6,000. Deposit B reached USD 30,000 in November and ended at the same amount. The two maxima total USD 48,000; the two year-end values total USD 36,000. Neither label should be silently substituted for the other.
The peaks may also have occurred on different days. Preserve dated statements and transfer records so the reviewer can distinguish individual account maxima from balances held at the same time. Do not subtract transfers from reportable account values on your own.
This matters when a CD matures into savings or money moves between institutions. Mark both sides of the transfer with a date and a reference to the supporting statements.
Label currencies before calculating
Write CAD beside a Canadian-dollar balance and USD beside a U.S.-dollar balance. An account's location does not establish its currency: an institution outside the United States may maintain a U.S.-dollar account.
Keep the original amount even after conversion. For FBAR, FinCEN describes converting the foreign-currency maximum using the applicable year-end rate in its valuation guidance. Income reporting may require a different conversion approach; let the preparer identify it rather than reusing a workpaper rate without checking.
Do not choose a Form 8938 threshold from one balance
Form 8938 thresholds depend on filing status and whether you satisfy the rules for living abroad. They also distinguish year-end value from value during the year. An address overseas alone does not establish the higher thresholds. The Form 8938 instructions explain the residence tests and filing requirements.
Provide filing status, residence and travel facts, and both sets of values. If you are unsure which form a prior preparer filed, request a copy instead of using a generic “foreign accounts” label. See the missing-CD filing checklist.
Mark gaps so they can be resolved
A blank should have an explanation: statement requested, institution changed, account identifier unconfirmed, or value awaiting review. An unknown balance is not a zero balance.
Give each unresolved question an owner and a next action. For example: “I will request the closing statement” or “Preparer to confirm whether the certificate is a separate account.” That turns a stack of statements into a manageable records request.
Keep original records according to the applicable retention rules. FinCEN's recordkeeping guidance identifies the account details that FBAR filers must retain.
Missing records? Rebuild the account map first
A missing statement does not stop an FBAR. A missing account map does. If your statements are gone, your organizer is half-finished, or your documents went to your preparer without labels, work in this order.
1. List every account that existed in each year. One row per account, one column per year. Include accounts that closed during a year, and include the savings account you had to open just to buy a certificate of deposit. Institutions do not always present that companion account as separate, but it usually is one. The FBAR account question follows the actual arrangement, not the marketing label.
2. Find the highest balance for each account and year. Not the December balance. The FBAR reports each account's maximum value during the calendar year, and FinCEN's line item instructions allow a reasonable approximation supported by periodic statements that fairly reflect the maximum. A year-end copy alone can miss a peak.
3. Document what you cannot prove. If a record is truly gone, write down the value used, where that number came from, and the assumption behind it. A documented best effort is evidence. A silent guess is not, and neither is a blank left as zero. For foreign-currency accounts, keep the original amount and record the conversion method and its source.
Then label everything you send: institution, account, year. Complete every tab of the organizer your preparer sends; a spreadsheet with several sheets is only useful when the sheets you did not see are filled in too. One labeled folder is worth more than twenty loose photos.
Where old foreign account records usually turn up
- Online banking archives. Many institutions expose 12 to 24 months of statements. Download PDFs, note the statement dates, and keep them with the account alias.
- A written statement request to the institution. Ask for full-year statements for a named account and mention that the account is for U.S. reporting. Some institutions charge a fee or take weeks; that is normal. A short request template is in the rebuild kit.
- Passbooks, certificates, and renewal notices. A passbook or a certificate photo can carry the account identifier, the term, and the interest credited. Keep the original file even after you transcribe the numbers.
- Transfer and closure records. Money bought a CD, rolled over, or moved when an institution changed? Keep both sides of the transfer with dates. Transfers do not reduce reportable account values, but they explain them.
- Prior filings and prior preparers. If a return or FBAR was filed before, the account list and confirmations are a starting point. Requesting a copy is faster than reconstructing from memory.
- Your own tax records. IRS transcripts can confirm which returns were filed and what income was reported, but foreign bank statements are not filed with the IRS, so a transcript does not replace a bank record.
What to do when a record cannot be obtained
FinCEN's instructions require the maximum account value of each reportable account and allow a reasonable approximation supported by periodic statements. When a period is genuinely unavailable, the practical standard is a value you can explain:
- Use the best evidence you have: partial statements, passbook entries, transfer records, interest credited.
- Write the number down with its source and the assumption you made.
- Flag it for review instead of silently guessing, and keep the note with your records. FBAR filers must retain records of each reportable account, including the account number, the institution, the account type, and the maximum value, generally for five years.
A house is not a foreign financial account
Real estate is not an FBAR account, and a home purchased abroad is not reportable as an account on that basis alone. What matters is where the money sits: a foreign bank or brokerage account that holds the proceeds is a reportable account question for its own reasons. Keep the purchase and transfer documents anyway; they explain the account activity.
Start with the free kit
Download the Foreign Account Records Rebuild Kit to organize the account map, the missing-record log, and the value-support notes on paper. Then use the free FBAR account workpaper in your browser for aliased accounts, dated balances, conversion rates, and evidence status.
If the account list, account structure, or the relevant years are still unclear, or if a prior FBAR appears to be missing, request a written reporting review. The preliminary intake is free, every intake is reviewed personally, and any preparation work is scoped and quoted in writing before it begins. Keep full account numbers and statements for the secure document process; do not send sensitive records through the public form.
Build your workpaper, then get help with the gaps
Open the free FBAR account workpaper to organize aliased accounts and supporting values. It runs in your browser and lets you print or download what you entered. It does not file an FBAR or evaluate Form 8938.
If the organizer exposes uncertainty about account ownership, CD structure, values, or overlapping forms, start a foreign accounts consultation. Bring the question list first; send sensitive supporting documents through the secure process after intake.
If a firm is asking you to move or liquidate investments after a move abroad, use the Canadian brokerage account-closure checklist to coordinate the institutions and advisers before acting.
Still unsure about your filing situation?
If this article raised more questions than it answered, that is normal.
Tell me the broad facts of your filing situation. I review your inquiry personally and explain the next step. Straightforward preparation may proceed to a written scope and quote. If substantive review is needed first, I may offer an optional paid assessment and explain the fee before you decide.
No tax documents in this form. Any paid work is agreed separately.
Frequently Asked Questions
Is my highest account balance the same as my year-end balance?
No. They answer different questions. Keep each account's supported annual maximum and its year-end value in separate columns, with the dates and records that support them.
Can I add Canadian-dollar and U.S.-dollar balances together?
Not as a meaningful dollar total without conversion. Label each account's currency, retain the original amounts, and record the appropriate conversion method and source for the filing being prepared.
Should I send full account numbers through the initial intake?
Use aliases and a general description for initial questions. Keep full account numbers and statements for FileAbroad's secure document process after intake.
Can I file an FBAR if I am missing old bank statements?
Often yes. FinCEN allows a reasonable approximation of each account's maximum value supported by periodic statements. Rebuild what you can from partial statements, passbooks, certificates, and transfer records, then write down the value used, its source, and any assumption. If the account structure or years are unclear, have the inventory reviewed before filing.
Do I need exact balances, or are estimates accepted?
The form asks for each account's maximum value during the year. FinCEN describes this as a reasonable approximation of the greatest value in the account, and periodic statements may be relied on when they fairly reflect that maximum. Keep the evidence behind every number; an unexplained estimate is a much weaker position than a documented one.
Can an IRS tax transcript replace my missing foreign bank records?
No. A transcript shows what was filed with the IRS. Foreign financial institutions do not report those account balances on U.S. information returns, so a transcript cannot reconstruct a foreign account's maximum value. It can still confirm your filing history.
Does my house in Ecuador belong on the FBAR?
No. Real estate is not a foreign financial account. The separate question is whether a foreign account that received or holds money related to the property, such as sale proceeds, is reportable for that year.
A CD and a savings account share one customer number. Is that one account or two?
Ask the institution in writing. A customer or membership number identifies the relationship; a deposit or certificate identifier identifies the account. Confirm how many actual accounts exist before preparing the report.
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About the Author
Chip Moreno is an American expat and PTIN holder based in Cuenca, Ecuador. He files his own FBAR and US return from Ecuador every year. For accepted engagements, you work directly with Chip through preparation and filing. Start with a short inquiry so Chip can review your situation and follow up.