FBAR filing — FinCEN Form 114

Foreign-account reporting starts with the accounts, not the form.

Start with account ownership, financial interest, signature authority and evidence of annual values.

FileAbroad AI agents check supported account evidence without human review. You confirm the facts; missing statement coverage or disputed values remain unresolved.

FBAR is filed separately through FinCEN. Any preparation or submission requires a connected supported workflow, separate accepted scope and your authorization; a ledger is not a filing.

Account evidence · Defined years · Customer fact confirmation

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

Records that define an FBAR scope

The filing years and accounts included in the engagement are confirmed before preparation begins.

Account roles

Account type, legal ownership, financial interest and signature authority, supported by records and customer confirmation.

Annual-value evidence

Statements, coverage gaps and conversion sources needed to evaluate annual maximum values. A partial statement does not establish a maximum.

Form 114 workpaper

The account facts and unresolved questions needed to scope FinCEN Form 114 work. The workpaper itself is not an FBAR.

Separate submission scope

FBAR preparation or submission requires a connected workflow, accepted terms and your authorization. A ledger export is not filing confirmation.

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.

Describe 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.

Related next step · Written plan

Need a written comparison of what was held and filed?

The Missed Account Reporting: Action Plan provides a fictional educational example of a source-indexed comparison and records-request plan. Its proposed $199 scope covers one selected historical year and up to 3 personal deposit accounts.

New intake and purchases are paused until that plan’s AI workflow is connected. No human review is offered. The example organizes facts; it does not decide filing obligations, relief eligibility, penalties, willfulness, or a correction route. Filing and full-year balance reconstruction are separately scoped.

View the fictional example and availability

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. 1

    List accounts and years

    Identify institutions, countries, ownership, signature authority and the available statements.

  2. 2

    Identify filing-history questions

    Keep missed years, tax-return omissions and IRS contact visible. Legal or willfulness questions require an external professional.

  3. 3

    Check value evidence

    Supported agents reconcile recorded values and currency sources. Missing coverage or conflicting values stay unresolved.

  4. 4

    Separate workpapers from filing

    Any Form 114 preparation or FinCEN submission must fit a connected workflow and a separately accepted scope.

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?

Agent evidence checks do not provide a legal opinion on willfulness. Possible willful conduct, criminal exposure or penalty defense requires a qualified external 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

Describe the accounts and filing history.

Include the years involved, account locations and types, and whether anything was filed previously. Keep the inquiry to broad facts. Account evidence checks and any preparation or submission require an available connected workflow and an accepted scope.

Contact FileAbroad

Ready to begin? Start intake

Do not send account numbers, bank statements, Social Security numbers, or other sensitive financial information through the public intake form or ordinary email.

FBAR Account Evidence & Filing Scope | FileAbroad | FileAbroad