FBAR Filing & FinCEN Form 114

Foreign bank and financial accounts can create U.S. reporting obligations even when no additional tax is due. Egan Tax helps U.S. citizens, residents, and other taxpayers determine whether an FBAR is required, identify the accounts that need to be reported, and address current or prior-year filing issues.

Work directly with Bill Egan for experienced guidance on foreign account reporting and related U.S. international tax matters.

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Who Needs to File an FBAR?

U.S. Citizens Living Abroad
Americans abroad may still have U.S. foreign-account reporting obligations even when they also file taxes in another country.

Dual Citizens
Having another citizenship does not automatically remove U.S. reporting requirements for foreign financial accounts.

Green Card Holders & U.S. Residents
Foreign bank, investment, or other financial accounts can trigger FBAR reporting even when the account is maintained outside the United States.

Foreign Account Owners or Signatories
An FBAR requirement can arise from financial ownership or, in some cases, signature authority over foreign accounts.

In general, a U.S. person may need to file an FBAR when the combined value of reportable foreign financial accounts exceeds $10,000 at any point during the calendar year.

What Foreign Accounts May Need to Be Reported?

FBAR reporting can apply to more than traditional checking and savings accounts. Depending on the facts, reportable foreign financial accounts may include:

  • Foreign checking and savings accounts

  • Foreign brokerage and securities accounts

  • Certain foreign mutual funds or pooled investments

  • Accounts with cash-value insurance or annuity products

  • Other financial accounts maintained outside the United States

Reporting can become more complex when accounts are jointly owned, held through an entity, or when someone has signature authority without owning the funds.

FBAR Filing Deadline

The FBAR is an annual report generally due April 15 following the calendar year being reported. If the April 15 deadline is missed, FinCEN provides an automatic extension to October 15 — no separate extension request is required.

FinCEN Form 114 is not filed with your federal income tax return. It is submitted electronically through FinCEN’s BSA E-Filing System.

The FBAR deadline and filing process are separate from the deadlines and extensions that may apply to your Form 1040.

FBAR and Form 8938

FBAR and Form 8938 are separate U.S. foreign-asset reporting requirements. Depending on the taxpayer’s situation, one form, the other, or both may be required.

FBAR / FinCEN Form 114

  • Filed separately with FinCEN

  • Focuses on foreign financial accounts

  • Uses its own reporting threshold and filing rules

  • Not attached to the federal income tax return

Form 8938

  • Filed with the federal income tax return

  • Covers specified foreign financial assets

  • Uses different thresholds depending on filing status and residence

  • Does not replace an FBAR requirement

Some foreign accounts may need to be reported on both forms, so the reporting requirements should be reviewed together rather than treated as interchangeable.

What If You Missed an FBAR?

Discovering that an FBAR should have been filed does not mean every taxpayer should handle the situation the same way. The right approach depends on the circumstances surrounding the missed filing.

  • Which years were missed

  • Whether related foreign income was properly reported

  • Why the FBAR was not filed

  • Whether other international information returns are also missing

  • The taxpayer’s overall filing and compliance history

FBAR violations can carry civil penalties, and the appropriate correction depends heavily on the facts. If multiple years or other international reporting forms are involved, it is worth reviewing the full situation before deciding how to correct the filings.

Some taxpayers with broader international filing issues may also need to consider available compliance procedures for prior-year corrections.

What Egan Tax Can Help With

  • Determining whether an FBAR filing requirement applies

  • Reviewing foreign bank and financial accounts

  • Identifying which accounts may need to be reported

  • Preparing FinCEN Form 114

  • Reviewing prior-year FBAR filing issues

  • Coordinating FBAR reporting with the federal tax return

  • Identifying possible Form 8938 or other international reporting requirements

  • Reviewing situations involving multiple years of missed reporting

FBAR issues often overlap with other areas of U.S. international tax. Egan Tax can review the broader filing picture so foreign account reporting is handled together with any related international tax obligations.

Frequently Asked Questions

  • Possibly. The $10,000 threshold generally applies to the combined value of applicable foreign financial accounts, not to each account separately. If the aggregate value exceeded $10,000 at any point during the year, an FBAR filing requirement may apply.

  • No. FBAR and Form 8938 are separate reporting requirements with different filing rules, thresholds, and definitions. Depending on your situation, you may need to file one or both.

  • No. FinCEN Form 114 is filed electronically with FinCEN rather than attached to your federal income tax return.

  • The standard deadline is April 15 following the year being reported. An automatic extension generally moves the deadline to October 15 without requiring a separate FBAR extension request.

  • The values of applicable foreign accounts are generally considered together when determining whether the reporting threshold has been exceeded.

  • The appropriate correction depends on the facts, including the years involved, whether foreign income was properly reported, and whether other international forms are missing. It is usually better to review the full filing history before deciding how to correct the issue.

  • FBAR-related account records generally should be retained for five years from the FBAR due date.

  • No. The $10,000 aggregate FBAR threshold is not doubled simply because spouses file a joint federal tax return. FBAR filing status is separate from income-tax filing status, so each spouse’s foreign-account reporting obligations must be considered under the FBAR rules, including jointly owned accounts.

  • In certain circumstances, yes. One spouse may file a single FBAR covering both spouses when all accounts the non-filing spouse is required to report are jointly owned with the filing spouse, the filing spouse reports those accounts on a timely filed FBAR, and both spouses complete and sign FinCEN Form 114a. If those conditions are not met, each spouse generally files a separate FBAR and reports the full value of jointly owned accounts.

  • FinCEN Form 114a, Record of Authorization to Electronically File FBARs, authorizes another person to electronically file an FBAR and is also used when eligible spouses file a single joint FBAR. The completed Form 114a is kept with the filer’s records and is not submitted to FinCEN with the FBAR, but it should be available if requested.

  • FinCEN does not charge a government filing fee to submit an FBAR through the BSA E-Filing System. Professional fees may still apply if an accountant, attorney, or other professional prepares or assists with the filing.

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