The FBAR (Foreign Bank Account Report), officially known as FinCEN Form 114, is a mandatory report for U.S. persons who have foreign financial accounts exceeding $10,000 in aggregate value at any point during the calendar year. While many taxpayers assume this only applies to traditional bank accounts, the definition of “foreign financial accounts” is broader. This guide provides a comprehensive list of accounts you must report on the FBAR in 2025—including newer and commonly overlooked assets.
📋 Who Is Required to File FBAR?
Before diving into the list, remember that you must file FBAR if:
- You are a U.S. person (citizen, green card holder, resident alien, or U.S. entity)
- You have a financial interest in or signature authority over one or more foreign financial accounts
- The aggregate value of all such accounts exceeded $10,000 at any time in 2025
🏦 Types of Accounts Reportable on FBAR
1. Foreign Bank Accounts
- Savings accounts
- Checking accounts
- Time deposits (e.g., foreign CDs)
- Joint bank accounts held with foreign relatives or associates
- Accounts at foreign branches of U.S. banks
2. Foreign Investment and Brokerage Accounts
- Mutual funds held in a foreign account
- Foreign brokerage accounts (stocks, ETFs, bonds)
- Foreign unit trusts
- Foreign hedge funds (in some cases)
3. Foreign Retirement and Pension Accounts
- Foreign pension plans (e.g., UK SIPP, Canada RRSP, Australia Superannuation)
- Employer-provided retirement accounts held abroad
- Voluntary retirement savings accounts in other countries
Note: Whether a foreign pension is reportable depends on the structure—check with a tax advisor familiar with the country’s retirement scheme.
4. Foreign Life Insurance and Annuity Contracts
- Foreign life insurance policies with cash value
- Whole life or universal life policies that accumulate investment income
- Foreign annuities with a cash component
5. Foreign Business and Trust Accounts
- Accounts owned by foreign corporations or partnerships where you have 50% or more ownership
- Trust accounts where you are a trustee or have control/signature authority
- Accounts you control through power of attorney or other means
6. Foreign Crypto Accounts (If Applicable)
- Crypto accounts on foreign exchanges may be reportable if they function like financial institutions (e.g., custodial wallets with fiat transactions)
- Cold wallets or hardware wallets are not currently FBAR-reportable
- The FinCEN position on crypto is evolving—monitor updates
Tip: When in doubt about crypto asset location or custody, consult a tax advisor familiar with international reporting rules.
🚫 What Accounts Are NOT Reported on FBAR?
- Domestic U.S. accounts
- Foreign real estate (unless held in an account)
- Direct ownership of stocks or securities not held in a foreign financial account
- Foreign credit cards
- Foreign social security benefits or government pensions (usually non-reportable)
🔑 Signature Authority vs. Financial Interest
You must report accounts even if they are not owned by you but you have signature authority—the ability to direct fund movement by communicating with the financial institution.
This includes company executives, power of attorney holders, and some employees with account access.
📐 Valuation and Currency Conversion
- Use the highest balance of each account during the year
- Convert values to USD using Treasury Year-End Exchange Rates
- Round to the nearest whole dollar
📅 FBAR Filing Details
- Form: FinCEN Form 114
- Due Date: April 15, 2025 (automatic extension to October 15)
- Where to File: Electronically at BSA E-Filing Portal
✅ Summary
FBAR requirements cover more than just checking or savings accounts. You must report a wide range of foreign financial assets—from investment and pension accounts to life insurance and possibly crypto. If the aggregate value of your foreign accounts exceeds $10,000, file FinCEN Form 114 by the deadline. With penalties for noncompliance reaching up to $100,000 or more, it’s better to err on the side of disclosure and get expert help if needed.
