FBAR & Foreign Account Reporting
An FBAR is required if the combined highest balance of your foreign financial accounts exceeded $10,000 at any point in the year. It is an information report filed with FinCEN, separate from your tax return, and no tax is due on it. Penalties for not filing are severe, which is why it matters.
What's included
- FinCEN Form 114 (FBAR) preparation and filing
- Form 8938 statement of specified foreign financial assets
- Determining which accounts and assets are reportable
- Signature authority reporting for business accounts
- Delinquent FBAR submission procedures
- Coordination with streamlined filing for taxpayers behind on returns
- Foreign pension and retirement account analysis
- Reporting for accounts held through foreign entities
Who this is for
Anyone with a bank account, brokerage account, or certain pensions outside the United States, including accounts they do not own but can sign on — a common trap for people who have signature authority over a parent's or employer's foreign account.
The $10,000 threshold is aggregate and it is the highest balance during the year, not the year-end balance. Several small accounts can cross it together, and an account that briefly held a property sale or an inheritance crosses it easily.
Deadlines and rules worth knowing
| Item | What applies |
|---|---|
| Threshold | $10,000 combined highest balance across all foreign financial accounts at any point in the year |
| Aggregate, not per account | Several smaller accounts count together toward the threshold |
| Highest balance | Measured at the peak during the year, not on December 31 |
| Where filed | With FinCEN, electronically, separately from your tax return |
| Signature authority | Reportable even if you do not own the account |
| Form 8938 | A separate IRS filing with different and generally higher thresholds. Many people must file both. |
| Penalties | Substantial even for non-wilful failures, and far higher where the failure is treated as wilful |
| Behind on filing | Delinquent FBAR procedures may allow catching up without penalty where there is no unreported income |
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Questions
What is the FBAR filing threshold?
You must file if the combined highest balance of all your foreign financial accounts exceeded $10,000 at any point during the year. The threshold is aggregate across accounts, not per account, and it is measured at the highest point in the year rather than the year-end balance. Many people cross it without realising.
Is the FBAR the same as Form 8938?
No, and many taxpayers must file both. The FBAR goes to FinCEN and covers foreign financial accounts. Form 8938 is filed with your tax return, covers a broader category of specified foreign financial assets, and has different and generally higher thresholds that vary with filing status and whether you live abroad.
What happens if I never filed an FBAR?
Penalties can be significant even where the failure was not wilful, so this should not be left alone. Where there is no unreported income associated with the accounts, delinquent FBAR submission procedures may allow you to file the missing reports without penalty. Where there is unreported income, streamlined procedures are usually the route.
Last reviewed 11 September 2026 by Fahadun Nabi, Founder, Blue Sage Tax and Accounting Inc.. General information, not advice for your specific situation.
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