Non-US Financial Accounts

Topics covered:

FBAR Only TQ - Does not ask income information

An FBAR (FinCEN 114) is a report sent to the US Treasury informing them of non-US financial accounts. To provide information for an FBAR, we ask that you answer YES to I have financial accounts outside the U.S. during TQ creation, or by clicking Select my income types after the TQ is created.

For the years in which you may not need to file a tax return, but need to file an FBAR we created an FBAR only TQ. This is commonly needed during the streamlined procedure program, for the 3 older years. The FBAR only TQ includes fewer questions than a regular TQ and is not sufficient if you are in need of a tax return for this year. 

For this shortened TQ, we do not need your income information. We need:

  • The Basics - basic information about yourself and your family
  • Where I live - information regarding your place of residence
  • Non-US Financial accounts - your non-US financial information for FBAR processing.

To create an FBAR Only TQ, click the gear icon at the left, then switch on Fbar Only toggle. 

If you want to have the FBAR prepared now and is going to provide tax return information later, please notify your accountant. If you need to file a return for the year in question, you can revert to a full TQ income question & more. Click the gear icon at the left, then switch off Fbar Only toggle.

Can I prepare the Form 8938 by myself?

Form 8938 is an integral part of Form 1040 and cannot be self-prepared as we are signing off on the project.

Do I have to provide you my non-U.S. bank account details?

If you would like us to prepare either

  • FinCEN Form 114 (FBAR)
  • Form 8938

then you have to list your foreign financial account details (such as bank accounts) on the Non-US Financial Accounts tab.

I had over $10,000 in one foreign account but have 2 other ones that were below the $10,000 threshold. Do I still need to report them all?

In a word - Yes.

As long as your  aggregate foreign bank account balance exceeded $10,000 at any point during the year, you have to report all your foreign bank accounts on FBAR.

The value of my foreign bank account only exceeded $10,000 for one day. Do I still have to file an FBAR?

Even one-day balance surges must be reported and an FBAR must be filed. Please note that the FBAR is not a tool for assessing your net worth.

The IRS is especially interested in instances where funds were transferred from one account to another.

Do I have to list my property on the list of Foreign Bank Accounts?

No, you only have to include balances on financial accounts (i.e. deposit, investment, pension or life insurance).

Property, precious metals, cash, art, etc. are not included.

Can I include the FBAR reporting fee when adding the sum of money into the Tax Preparation Fee question box?


I am a signatory on two current accounts at work (or any other accounts that are not my own). Should I include these?

According to FBAR rules, you should include them as non-personal accounts to which you have a signatory authority only.

Is a PRSA (Personal Retirement Savings Account) a savings account or a pension? It's a supplemental savings account, not the pension.

The account is considered a retirement account as long as there are age limitations to begin withdrawals from it.

My insurance policy / pension policy does not have a cash value. I only know the amount that will be disbursed upon my retirement or death. Do I have to report this account on FBAR/FATCA?

If an insurance or pension has no current value and only provides a defined benefit at a future date, this account is not reported on FBAR/FATCA.

I have a brokerage account number, but the same account number holds investment in multiple mutual funds. Should I report the total value of all funds under the account number, or should list them separately?

Please report total value held inside the brokerage account together.

Account #12345
Balance = Fund A + Fund B + Fund C

Do I have to provide information about the number of foreign stock that I own or their market value?

You may have to declare the  account in which you hold the stocks (such as a brokerage account) if it is located outside the United States and your total non-US financial holdings are over the threshold required to file Form 8938.

You do not, however, have to report the actual stock holdings that you hold.

If you sell stocks, the sales do have to be reported on your tax return.

If you own more than 10% of a foreign company (i.e. probably a private company) it must be reported on the Form 8938.

Do I need to report my child's bank account (which has a balance of over $10,000) on my FBAR?

  • If you are listed on the account as a guardian with signatory authority, then you have to report this account on your FBAR.
  • If you do not have signatory authority over the account, you do not have to list it on your FBAR.
  • If your child is a U.S. citizen you must file an FBAR on their behalf regardless of the child's age and regardless of your own signatory authority.

I own bank "Les parts sociales" - membership parts. How should they be reported?

Les parts sociales are shares of bank capital that account holders may own like shares of any other company.

Share ownership does not need to be reported.

Passive income received from those shares should be reported as foreign qualified dividends.

I have a savings account at my bank directly linked to our mortgage payment saving account. Should it be reported on FBAR / FATCA?

The accounts designated for mortgage payment are reported on FBAR and balance is included in the calculation of the FATCA threshold.

Share in foreign companies reporting

Example: You own more than 50% of the shares in a foreign company. That company, in turn, owns less than 50% of a second foreign company. You have a signature on the bank account of this second company. Do you have to report the second company account on FBAR?

In this case, bank account for the first company is reported as your personal account because you have control ownership over 50%.

Bank account for the second company is reported separately as account for which you have signatory authority but no control.

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