Table of contents:
What is FBAR and who must file FinCEN Form 114
The Foreign Bank Account Report (FBAR), also known as FinCEN Form 114, requires U.S. persons to report foreign financial accounts to the U.S. Treasury when the aggregate value of these accounts exceeds $10,000 at any time during the calendar year. This includes checking, savings, investment accounts, money market funds, offshore structured entities, and others listed below.
The FBAR is an informational return and does not involve paying taxes, but failing to report foreign accounts can lead to severe penalties.
You must report all foreign financial accounts you own, or over which you have a financial interest or signature authority, if the combined balance exceeds $10,000 at any point during the previous calendar year — even if only one account had a balance above the threshold for a single day while the others had zero balances throughout the year. The IRS is particularly interested in cases where funds are transferred between accounts.
The IRS and U.S. Treasury have mechanisms to identify individuals with foreign bank accounts. They actively pursue delinquent taxpayers and enforce payment of outstanding taxes. Through information-sharing agreements with many countries, they conduct investigations and gather data on foreign accounts. Additionally, they receive information through a whistleblower program and their overseas criminal investigation teams.
Since January 2015, the IRS has been receiving comprehensive information about foreign financial accounts directly from participating Foreign Financial Institutions (FFIs). These institutions are obligated to report your name, address, U.S. Tax Identification Number (TIN), foreign bank account number, account closures from 2013 to the present, end-of-year balance, and gross account earnings.
Refer to the Difference between FinCEN 114 and Form 8938 and the IRS comparison of FATCA and FBAR requirements for more information.
Types of accounts reported on FBAR (FinCEN Form 114)
You are required to report the following types of foreign financial accounts if you own them, have a financial interest, or signature authority over them:
Non-U.S. joint accounts: If you share a foreign account with someone else (e.g., a spouse), you must report the account if the aggregate value exceeds the $10,000 threshold, regardless of how much of the account you own.
Non-U.S. zero-balance accounts: Must be reported if the combined balance across all accounts exceeds $10,000 at any time during the year.
Non-U.S. accounts with signature authority only: Even without ownership (e.g., over your child’s account), you must report accounts if you have the authority to manage or direct withdrawals.
Non-U.S. financial account over which you have signature authority: Even if you do not have an ownership interest in the account (e.g., your son's or daughter's account), you must report foreign accounts if you have signature authority over the account, meaning you can direct withdrawals or manage the account.
Non-U.S. bank account: Includes checking or savings accounts, and certificates of deposit held at a foreign bank or a foreign branch of a U.S. bank.
Non-U.S. investment account: Includes accounts holding stocks, bonds, options, futures, and other derivative instruments, held in your name by a foreign financial institution.
Non-U.S. business account: A bank account held by a non-U.S. business entity (corporation or partnership) in which you own more than 10% of the ownership interest.
Non-U.S. insurance/annuity: Includes foreign life insurance policies with cash value (e.g., whole life insurance) and annuity contracts with cash value. Note that car, health, and home insurance policies — unless they have an associated cash value or investment component — are not reportable on the FBAR.
Non-U.S. retirement plan: Includes foreign pensions (either employer-provided or self-managed). If the plan is a defined benefit plan (i.e., no account balance, and benefits are determined by a formula), report the total value of any distributions you received during the year as the highest balance. If no distributions were made, defined benefit plans are not reportable on the FBAR. Examples of defined benefits plans are survivor benefits and government employee pensions earned by working for the government.
Non-U.S. trust accounts: Accounts of a foreign trust that you created, are the grantor of, or exert power over. You also need to report trust accounts of which you're a beneficiary and the trust grantor is not a US citizen.
Non-U.S. escrow accounts: Reportable if you have signature authority or a financial interest. This includes the ability to withdraw or direct the use of funds.
Non-U.S. mutual funds: Note that PFIC Form 8621 filing may apply in some cases.
Government-mandated Social Security funds: Report only if the fund is privately operated and tied to a specific account balance based on your contributions. Government-only funds are not reportable.
❗ Important notes:
Foreign real estate, precious metals, cash, and art are not reportable on the FBAR.
If you do not hold any foreign bank accounts, there is no requirement to prove the absence of such accounts.
If you closed a foreign account during the tax year, you still need to report it and its final balance.
If you are applying for the IRS Streamlined Procedures program, you have to file 6 years of FBAR, regardless of the balances in those accounts.
FBAR filing by spouses
Assuming both spouses are U.S. citizens or Green Card holders:
If both spouses only have joint accounts, they can file a single FBAR together.
If one spouse has foreign accounts requiring FBAR reporting and the other is a joint owner without any foreign accounts, they can file one FBAR together.
However, if both spouses have at least one individual foreign account, spouses must file FBARs separately (two FBARs in total).
Reporting child's bank account
If you are listed as a guardian with signatory authority on the account, you must report this account on your FBAR.
If you do not have signatory authority over the account, you do not need to list it on your FBAR.
If your child is a U.S. citizen, you must file an FBAR on their behalf, regardless of their age and your signatory authority.
How to prepare and file FBAR (FinCEN Form 114)
You can e-file your FBAR on your own since it is a standalone form and is not submitted as part of your tax return. Refer to the U.S. Treasury instructions.
However, we do not recommend doing it yourself for the following reasons:
Accuracy matters: While the form itself isn’t overly complex, it must be 100% correct to avoid IRS scrutiny or rejection. Think of it as assembling a puzzle without clear instructions — one small mistake could lead to issues.
Time-consuming process: Filing requires setting up an account on the U.S. Treasury’s online system and navigating multiple steps.
Constant regulation changes: FBAR reporting rules frequently change, and most taxpayers aren’t aware of these updates. Our team stays on top of these changes year-round, so you don’t have to.
If you would like TFX to prepare your FBAR (FinCEN Form 114), log in to your TFX account, request our FBAR filing service, and list your foreign financial account details (including retirement plans, i.e., pension accounts).
Note: if you participate in the Streamlined Foreign Offshore Procedures Program, you will need to complete three standard Tax Questionnaires and three FBAR-only Questionnaires (a short version of our standard TQ). In this case, you don't need to request our FBAR filing service — your six FBARs will be e-filed by your assigned tax preparer.
Extension of time to file FBAR
The due date for filing FinCEN Form 114 (FBAR) is April 15. However, the Treasury Department automatically grants a 6-month extension until October 15 — no separate extension request is required. For the most up-to-date filing deadlines, please refer to Tax due dates and deadlines.
What to do if you failed to file an FBAR
If you were required to file an FBAR but failed to do so, your next steps depend on whether you reported all foreign account interest on your original tax return and whether additional reporting is required:
If all interest from foreign bank accounts was reported on your original tax returns, file the FBAR using the Delinquent FBAR Submission Procedures without amending your tax returns.
If interest from foreign accounts was not included in your tax returns, file amended tax returns and submit FBAR reports through the Streamlined Foreign Offshore Procedures (SFOP). For pricing details, please refer to SFOP services pricing on our website.
'Acknowledged’ FBAR reports
'Acknowledged' is the final stage of the FBAR filing process. The Treasury does not 'accept' the report but merely buys it. If your tax preparer has provided you with a filing confirmation that says 'acknowledged,' please process the final signoff.
How to verify if FBAR was filed (similar to a tax transcript)
If you file the FBAR electronically, you receive a confirmation (Acknowledgement) with a tracking number (BSA ID). This is your proof of submission.
If you still need to confirm whether your FBAR was filed, you can contact the FBAR Helpline. Be prepared to provide your filing information, such as your name, date of filing, and tracking number:
U.S. callers can dial 866.270.0733 (toll-free number).
International callers can dial +1.313.234.6146 (not toll-free).
Working hours are 7 AM to 3 PM CT, Monday to Friday.
Alternatively, you can submit a verification request in writing. The request should include the filer's name, Taxpayer Identification Number, and the filing period. There is a $5.00 fee for verifying five or fewer forms and an additional $1.00 fee for each additional form. If copies of the forms are needed, there is an extra fee of $0.15 per copy. Checks or money orders in USD should be made payable to the United States Treasury. The written request and payment should be mailed to the following address:
IRS Detroit Computing Center, P.O. Box 32063, Detroit, MI 48232 Attn.: Verification