Report of Foreign Bank and Financial Accounts

Who Files Form 114 (FBAR)

Every US person (citizen, resident alien, US-formed entity) with signature authority or financial interest in foreign financial accounts whose aggregate value exceeded $10,000 at any point during the calendar year. This includes joint accounts, accounts held by foreign affiliates, and certain insurance and pension accounts.

What Form 114 (FBAR) Reports

The FBAR is filed electronically with the Financial Crimes Enforcement Network (FinCEN), separate from the federal income tax return. The threshold is $10,000 aggregate across all foreign accounts on any single day. Penalties for non-willful violations can reach $10,000+ per violation; willful violations can incur penalties of the greater of $100,000 or 50% of the account balance per violation.

Key Deadlines

• April 15: annual filing deadline
• Automatic extension to October 15 (no separate extension form required)

Common Mistakes

• Missing the FBAR while still filing Form 8938: they are separate, parallel obligations
• Not aggregating accounts when calculating the $10,000 threshold
• Missing signature authority over employer or family member accounts
• Failing to use the IRS Streamlined Filing Compliance Procedures for non-willful late filers

Best Practices

• File even if you are not sure the threshold was crossed. Aggregating across all foreign accounts on any one day is the correct test, and overreporting has no penalty.
• Include accounts where you have signature authority, not just ownership. Foreign accounts of an employer, family member, or trust where you can sign count.
• Use the IRS Streamlined Filing Compliance Procedures if you missed prior years, before the IRS contacts you. Streamlined Foreign Offshore is no-penalty for non-residents; Domestic is 5 percent.
• Keep a record of the maximum value during the year for each account. The reporting requires highest balance, not year-end balance.
• Set a recurring annual reminder for April 15 (auto-extended to October 15). Missed FBARs are a top reason taxpayers face Streamlined Procedures later.

Source: Official Form 114 (FBAR) information at FinCEN.gov