FBAR (Foreign Bank Account Report), officially FinCEN Form 114, isn’t just for individuals. U.S. entities—including trusts, corporations, partnerships, and limited liability companies (LLCs)—may also be required to report foreign financial accounts. This guide explains the FBAR filing requirements for entities, including foreign subsidiaries, disregarded entities, and U.S. businesses with overseas accounts.
🏢 Which Entities Must File FBAR?
Any U.S. entity that has a financial interest in or signature authority over foreign accounts with an aggregate value exceeding $10,000 at any time during the calendar year must file an FBAR.
- Corporations
- Limited Liability Companies (LLCs)
- Partnerships
- Trusts and estates
- Disregarded entities for tax purposes (still considered separate for FBAR)
Note: Even if an entity does not file a separate federal income tax return (e.g., single-member LLCs), it may still need to file an FBAR.
💰 What Accounts Must Be Reported?
FBAR reporting includes all foreign financial accounts in which the entity has:
- A direct financial interest (e.g., the entity is the named account holder)
- Indirect financial interest (e.g., foreign subsidiaries or trusts)
- Signature or other authority (e.g., ability to control account activity)
Account types include foreign bank accounts, securities accounts, mutual funds, foreign pensions, and life insurance with cash value.
🌐 Reporting for Foreign Subsidiaries and Affiliates
If a U.S. parent company has control over a foreign subsidiary that holds qualifying foreign accounts, it may need to file FBARs if it has:
- Ownership of more than 50% of the subsidiary
- Signature authority over the accounts
- The ability to direct the disposition of account funds
Note: Foreign subsidiaries themselves are not “U.S. persons” and are not required to file unless treated as U.S. entities for tax purposes.
🔍 FBAR Rules for Trusts
Trusts must file FBARs if they are:
- U.S.-domiciled trusts with foreign accounts
- Trustees or grantors who are U.S. persons with financial interest or control
- Beneficiaries who have a present financial interest and are U.S. persons
Example: A U.S. trust with a Swiss brokerage account must file an FBAR if the account value exceeded $10,000 at any point during the year.
📋 How to File an FBAR for an Entity
Entities must file FBAR electronically through the BSA E-Filing System. Filing requires:
- Entity name, EIN or SSN (if applicable), and address
- Information on each foreign account (bank name, number, address)
- Maximum account value during the calendar year (converted to USD)
- Account type and whether the entity has financial interest or signature authority
⚠️ Reporting for Disregarded Entities
Even if a business is classified as a disregarded entity for federal tax purposes (such as a single-member LLC), it is treated as a separate “person” for FBAR reporting.
Key Rule: A U.S. single-member LLC must file its own FBAR if it holds or controls qualifying foreign accounts.
📅 Deadline for Filing
- Initial Deadline: April 15, 2026 (for the 2025 calendar year)
- Automatic Extension: October 15, 2026
- No separate request needed—the extension applies automatically
📚 Recordkeeping Requirements
Entities must maintain records of each foreign account reported on the FBAR for at least 5 years. Records should include:
- Account number
- Bank name and address
- Account type
- Maximum balance during the year
🔄 Consolidated FBAR Filing
U.S. entities that own or control multiple subsidiaries may file a consolidated FBAR. Conditions include:
- The parent entity must own >50% of each subsidiary
- All entities included must be eligible U.S. persons
- Signature authority filers may be included, if applicable
💡 Common Scenarios
Scenario 1: U.S. Corporation with German Bank Account
A U.S.-based software company holds €30,000 in a German business checking account. The company must file an FBAR to report the account, using the year-end U.S. Treasury FX rate for conversion.
Scenario 2: U.S. Trust Controlled by a U.S. Grantor
A U.S. citizen forms a foreign trust with a Luxembourg account. The trust and/or the grantor must file FBARs depending on control, interest, and residency status.
⚖️ Penalties for Non-Compliance
Failure to file an FBAR can lead to steep civil and criminal penalties:
- Non-willful violations: Up to $10,000 per violation
- Willful violations: Greater of $100,000 or 50% of the account value
- Criminal prosecution: In cases of fraud, concealment, or obstruction
✅ Final Thoughts
Trusts, corporations, LLCs, and other entities are just as responsible as individuals when it comes to FBAR compliance. Even if an entity is a pass-through for income tax purposes, it must file its own FBAR if it owns or controls foreign financial accounts exceeding $10,000. Ensure proper documentation, timely filing, and awareness of consolidated filing options to stay compliant and avoid costly penalties.
