FBAR filing — FinCEN Form 114
Foreign-account reporting starts with the accounts, not the form.
FileAbroad prepares FinCEN Form 114 for U.S. persons with reportable foreign financial accounts.
I review the accounts involved, ownership or signature authority, maximum values, filing years, and prior filing history before preparing the accepted FBAR work.
FBAR is filed separately from the federal income-tax return through FinCEN's electronic filing system.
Account review · Defined filing years · Client review before submission
The filing rule
When an FBAR is generally required
A U.S. person generally must file an FBAR when the person has a financial interest in, or signature or other authority over, one or more foreign financial accounts and the aggregate value of the reportable foreign financial accounts exceeds $10,000 at any time during the calendar year.
Foreign financial accounts can include accounts such as foreign bank accounts, brokerage accounts, and mutual-fund accounts. Whether an account produced taxable income does not determine whether the account is reportable for FBAR purposes.
The filing analysis still depends on the account, ownership or authority, location, and applicable exceptions.
The $10,000 test
The threshold applies across the accounts.
The $10,000 threshold is not applied separately to each account.
The maximum values of the reportable foreign financial accounts are considered together. If their aggregate value exceeds $10,000 at any time during the calendar year, the FBAR filing requirement may apply even when no single account exceeded $10,000 by itself.
Each reportable account still needs its own maximum value determined for the year and converted to U.S. dollars using the applicable reporting method.
Preparation
What an accepted FBAR engagement includes
The filing years and accounts included in the engagement are confirmed before preparation begins.
Account review
Review of the account types, ownership, financial interest, and signature or other authority facts provided for the accepted filing years.
Maximum values
Organization of the maximum account values needed for the accepted FBAR filings and conversion to U.S. dollars using the applicable reporting method.
FinCEN Form 114 preparation
Preparation of the accepted current-year or delinquent FBAR filings using the information and records provided.
Client review
You review the completed FBAR information before submission and have an opportunity to correct the account information.
Electronic filing and records
After authorization, the accepted FBAR is filed electronically and you receive a copy and the available filing confirmation for your records.
Account records
What I need for each reportable account
The exact request depends on the filing years and accounts involved.
For each reportable account, the information generally includes:
- Name on the account
- Account number or other account designation
- Name and address of the financial institution
- Type of account
- Maximum account value during the calendar year
Additional ownership or signature-authority information may be needed depending on the account.
Do not submit account numbers or financial statements through the public intake form or ordinary email. Secure upload instructions are provided after the engagement is accepted.
Prior years
What if an FBAR was filed late — or not filed at all?
A late or missing FBAR should not be treated as an ordinary current-year filing without first reviewing the surrounding facts.
The IRS directs taxpayers who have not been contacted about a late FBAR and are not under civil or criminal investigation to file delinquent FBARs as soon as possible and explain the reason for filing late. When another compliance procedure applies, such as the Streamlined Filing Compliance Procedures, the instructions for that procedure control the FBAR filing.
Tell me about the filing history, whether the related income was reported on the U.S. tax return, any prior IRS contact, and any concern about the circumstances of the missed filing before preparation begins.
FileAbroad can prepare accepted delinquent FBAR work, but I do not provide legal opinions about willfulness, criminal exposure, or penalty defense.
Separate reporting systems
FBAR and Form 8938 are not the same filing.
FBAR is filed separately with FinCEN. Form 8938, when required, is filed with the taxpayer's federal income-tax return.
The two filings have different thresholds, definitions, and reporting rules. Depending on the taxpayer's facts, one filing may apply, both may apply, or neither may apply.
The process
How it works
- 1
Tell me about the accounts and filing years.
Start with the intake and describe the countries, account types, ownership or authority, and filing history without sending account numbers or statements through the public form.
- 2
Consultation and review.
We review the account facts, filing history, and any issue that may affect the appropriate preparation path.
- 3
Scope and records.
If FileAbroad can accept the work, I confirm the filing years, records needed, scope, and price before preparation begins.
- 4
Secure document collection.
You provide the requested account information and supporting records through the secure upload process.
- 5
Preparation and review.
I prepare the accepted FBAR filings and you review the completed account information before submission.
- 6
Electronic filing.
After authorization, the accepted FBAR filings are submitted electronically and you receive copies and the available filing confirmation.
Before you start
Questions about FBAR filing
Is the $10,000 FBAR threshold per account?
No. The threshold is based on the aggregate value of the reportable foreign financial accounts. If the combined value exceeds $10,000 at any time during the calendar year, an FBAR filing requirement may apply even when each individual account remained below $10,000.
Does an account matter if it earned no income?
It can. The IRS states that whether a foreign financial account produced taxable income has no effect on whether the account is a foreign financial account for FBAR purposes. The filing analysis depends on the account and the taxpayer’s financial interest or authority over it.
Is FBAR filed with my tax return?
No. FBAR is FinCEN Form 114 and is filed electronically through FinCEN’s BSA E-Filing System. It is separate from the federal income-tax return.
What if I missed FBARs for prior years?
The filing history and surrounding facts should be reviewed before choosing the preparation path. Delinquent FBARs may be filed under the ordinary late-FBAR instructions or as part of another applicable compliance procedure, depending on the taxpayer’s circumstances.
Are cryptocurrency accounts reportable on FBAR?
FinCEN’s current published guidance states that a foreign account holding only virtual currency is not reportable on the FBAR under the existing regulations unless the account also holds reportable assets. FinCEN has previously stated that it intends to amend the regulations regarding virtual-currency reporting, so current FinCEN guidance should be checked for the filing year involved.
Can FileAbroad tell me whether a late filing was willful?
FileAbroad can review the filing facts for preparation and scoping purposes, but I do not provide a legal opinion about whether conduct was willful or non-willful. A matter involving possible willful conduct, criminal exposure, or penalty defense may require another professional.
Primary sources
Current FBAR guidance
FBAR is administered under the Bank Secrecy Act and filed through FinCEN. Current IRS and FinCEN guidance should be used for filing rules and procedures.
Start here
Tell me about the accounts and filing history.
You don't need to determine the FBAR filing path yourself. Tell me which years are involved, where the accounts are located, the types of accounts, and whether anything was filed previously. I'll review whether a FileAbroad consultation appears to be the appropriate next step.
Tell Me About My SituationPrefer email? info@fileabroad.com
Do not send account numbers, bank statements, Social Security numbers, or other sensitive financial information through the public intake form or ordinary email.