Compliance
Foreign Account Records: A Checklist for Your Tax Preparer
Prepare one account inventory with separate fields for currency, supported annual maximum, year-end value, income, and prior filings. Keep the evidence for each number and flag anything you have not confirmed.
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.
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.
Tax rules depend on your exact facts: your country, your income, your accounts, your filing history. I review every intake personally and reply within one business day. If FileAbroad can accept the work, we schedule a paid consultation and you receive a written scope before any preparation begins.
No tax documents here — just the broad facts.
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.
Continue with a guide
Guide
Crypto Taxes for Americans Abroad: Digital Assets, Foreign Exchanges, and Wallets
A fact-based U.S. tax guide for expats holding cryptocurrency, covering sales, staking, foreign exchanges, Form 8938, FBAR questions, and recordkeeping.
Guide
Inherited Foreign Property Sale: U.S. Tax and Reporting Guide
A records-first map of inherited basis, Form 3520 questions, foreign-property sale gain, currency, rental use, foreign tax, and account reporting for U.S. taxpayers.
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. Most expat tax firms are call centers in Ohio — Chip does the opposite: you work directly with him from first review to filing. Every engagement starts with a paid consultation or reach out here.