Many U.S. expatriates living abroad are surprised to learn they must file the FBAR (FinCEN Form 114) to report their foreign bank accounts—even if they are no longer living in the U.S. or the accounts aren’t active. To help simplify compliance, we’ve compiled answers to the most frequently asked questions (FAQs) about FBAR filing obligations from U.S. citizens and green card holders living overseas.
📌 1. Do I Have to File FBAR If I Live Abroad?
Yes. U.S. citizens, green card holders, and residents must report foreign financial accounts if the aggregate value of all accounts exceeds $10,000 at any time during the calendar year, regardless of where they live.
🏦 2. What Types of Accounts Must Be Reported?
You must report:
- Foreign bank accounts (checking, savings)
- Foreign brokerage and investment accounts
- Foreign pension or retirement accounts (in many cases)
- Foreign mutual funds and pooled investment vehicles
- Foreign life insurance policies with cash value
- Accounts where you have signature authority but no ownership
🚫 3. Do I Need to Report Closed Accounts?
Yes, if they were open at any point during the calendar year and the value exceeded the $10,000 threshold. You do not need to report accounts that were closed before January 1 of the reporting year.
💤 4. What If My Account Had No Activity?
FBAR filing is based on account value—not activity. Even if the account was inactive or dormant, you must report it if the value exceeded the $10,000 aggregate threshold.
🔄 5. Do I Have to Report Foreign Accounts That I Jointly Own with a Non-U.S. Spouse?
Yes. If you are a U.S. person and the account is held jointly (even with a non-U.S. spouse), and the value contributes to the $10,000 aggregate, it must be reported.
💳 6. Do I Report My Foreign Credit Card or Prepaid Account?
No. Credit card accounts and prepaid debit cards (not associated with deposit accounts) are generally not reportable unless they have stored cash balances in deposit-like structures. If in doubt, consult a tax professional.
📅 7. What Is the FBAR Deadline?
The FBAR deadline is April 15, with an automatic extension to October 15. You do not need to file a separate extension form to receive this extension.
💱 8. What Exchange Rate Do I Use?
Use the U.S. Treasury’s year-end exchange rate for December 31 of the reporting year. You can find it on the Treasury website. Do not use commercial or IRS rates unless the currency is not listed by Treasury.
📝 9. What Happens If I Forget to File FBAR?
If you missed your FBAR filing, you may still qualify for Delinquent FBAR Submission Procedures if you weren’t contacted by the IRS yet and have reasonable cause. Timely voluntary disclosure can help avoid penalties.
🖊️ 10. I Only Have Signature Authority—Do I Still Report?
Yes. If you have signature authority over a foreign account (but no financial interest), you must still file an FBAR if the aggregate value of all accounts exceeds $10,000. This includes company officers, attorneys-in-fact, or employees with transactional authority.
💼 11. Do I Need to Report My Employer’s Foreign Accounts?
If you have signature authority over your employer’s foreign accounts, and the aggregate value exceeds $10,000, you may need to report them—unless an exemption applies (e.g., for publicly traded companies).
🧮 12. How Do I Calculate the “Maximum Value” of Each Account?
Use the highest balance at any point during the year—not the average or year-end balance. Review all monthly or quarterly statements to determine this peak value. Then convert to USD using the Treasury exchange rate.
🌍 13. What If I Have Accounts in Multiple Currencies?
Convert each account’s maximum balance to USD using the official Treasury FX rate for that currency on December 31. Then total them to see if the $10,000 threshold is met.
📂 14. Do I Have to File FBAR Every Year?
Yes—if the aggregate value of your foreign accounts exceeded $10,000 in any calendar year, you must file an FBAR every year it applies. There is no “once-and-done” rule.
🧾 15. Does FBAR Affect My U.S. Taxes?
Not directly. FBAR is an informational report and does not trigger a tax bill. However, failure to file may subject you to civil and even criminal penalties.
🚨 16. What Are the Penalties for Not Filing FBAR?
- Non-willful violation: Up to $10,000 per violation
- Willful violation: Greater of $100,000 or 50% of account value
- Criminal penalties may also apply in cases of intentional concealment
✅ Final Takeaway
If you’re a U.S. expat or green card holder with foreign financial accounts, understanding FBAR reporting requirements is critical to staying compliant. Even if your accounts are small, inactive, or jointly owned with non-U.S. persons, they may still trigger a filing obligation. The best approach is to keep detailed records, file every year, and consult a tax advisor if your situation is complex.
