When filing FinCEN Form 114, also known as the Foreign Bank Account Report (FBAR), it’s important to understand the rules around jointly owned or co-signatory foreign financial accounts. U.S. persons—including married couples, business partners, and even parents of minors—must follow specific reporting protocols to ensure full compliance. This guide outlines when and how to report co-owned foreign accounts and the implications for different ownership scenarios.
💡 What Is a Joint or Co-Owned Account?
A joint or co-owned account refers to any foreign financial account where more than one person has a financial interest or signature authority. This includes:
- Spouses with joint ownership
- Parents and children holding accounts together
- Business partners or officers with signature authority
FBAR rules apply to each individual U.S. person who meets the $10,000 aggregate threshold—even if they share an account with someone else.
👩❤️👨 Married Couples: Joint FBAR Reporting
Married couples can file jointly or separately, depending on their specific situation:
Option 1: One Spouse Files for Both
- Only available if the non-filing spouse has no other foreign accounts to report
- The filing spouse must include all jointly held accounts
- The non-filing spouse must complete Form 114a (Record of Authorization to Electronically File FBARs)
- Form 114a does not need to be submitted, but it must be retained for records
Option 2: Both Spouses File Individually
- Each spouse files a separate FinCEN Form 114
- Each must report the full value of any jointly owned accounts
🏢 Business Co-Signers and Signature Authority
U.S. persons with signature authority only—but no financial interest—over foreign accounts must also file the FBAR if the $10,000 threshold is met. This applies to:
- Employees or officers authorized to move funds
- Accountants or legal professionals with power-of-attorney
If the filer only has signature authority (and not financial ownership), they must indicate this clearly in the FBAR form by selecting “Signature Authority” under account type.
👶 Reporting Accounts Held by or for Minors
Foreign financial accounts held by a minor child must also be reported if they meet the filing threshold. The responsibility falls on the child’s parent, guardian, or other person legally responsible for the child.
- File a separate FinCEN Form 114 under the child’s name and SSN/ITIN
- The parent/guardian signs on behalf of the child
- Use the online BSA e-filing system for submission
💲How to Report Joint Accounts on FBAR
For each joint account, enter the full maximum value of the account during the calendar year. Do not divide or allocate the balance between owners.
Required Information Includes:
- Account number and type
- Maximum account value (in USD)
- Financial institution name and address
- Co-owner names and TINs (if available)
🔁 Example Scenarios
Example 1: Joint Spousal Account
Spouse A and Spouse B co-own a foreign bank account with a 2025 maximum value of $50,000.
- Spouse A files FBAR for both (if Spouse B has no other accounts) and includes the $50,000 account
- Form 114a must be signed and retained
Example 2: Business Account with Signature Authority
John is CFO of an international company and has signature authority over a $1 million foreign account he doesn’t own.
- John must file FBAR disclosing his authority
- He marks the account as “signature authority” on FinCEN Form 114
⚠️ Penalties for Failing to Report Joint Accounts
- Non-willful violation: Up to $10,000 per violation
- Willful violation: Greater of $100,000 or 50% of account balance
- Applies per person, per account, per year
📌 Best Practices for Reporting Co-Owned Accounts
- Keep detailed records of account ownership and access
- Use official Treasury FX rates to convert foreign currency
- Coordinate with co-owners to avoid duplicate or inconsistent reporting
- Retain signed Form 114a if one spouse is filing on behalf of both
- Consult a tax advisor for complex joint ownership structures
✅ Summary
Reporting foreign accounts jointly held with a spouse, child, or business associate requires careful attention to ownership and signature authority rules. Whether you’re filing individually or jointly, always disclose the full account value and retain documentation. Proper FBAR compliance helps avoid costly penalties and protects your financial transparency in the eyes of the IRS and FinCEN.
