FBAR filing catches many people by surprise. The $10,000 threshold is lower than you might expect, and the definition of “U.S. person” is broader than most realize. Here’s how to determine if you have an FBAR filing requirement.
Who Must File FBAR
- U.S. citizens, residents, and certain entities
- With financial interest in OR signature authority over foreign accounts
- When aggregate value exceeds $10,000 at any time during the year
- Includes: bank accounts, securities accounts, mutual funds, foreign pensions (sometimes)
- File even if no income earned and no taxes owed
Table of Contents
U.S. Person Definition for FBAR
You’re a “U.S. person” for FBAR purposes if you are:
- U.S. citizen (including dual citizens living abroad)
- U.S. resident alien (green card holder)
- Person meeting substantial presence test (enough days in the U.S.)
- U.S. trust or estate
- Domestic entity (corporation, partnership, LLC formed in the U.S.)
The rules are based on tax residency, not just citizenship. A green card holder living in another country is still a U.S. person. A dual citizen who has never lived in the U.S. is still a U.S. person.
For residency rules, see Form 1040-NR Guide.
The $10,000 Threshold Explained
The $10,000 threshold works differently than many people assume:
| Question | Answer |
|---|---|
| Is it per account? | No, aggregate of ALL accounts |
| When measured? | Maximum at any point during the year |
| Average or maximum? | Maximum value |
| What if briefly over? | Still must file |
| Joint accounts? | Full value counts for each owner |
Example: You have three foreign accounts:
- Account A max: $6,000
- Account B max: $3,000
- Account C max: $2,000
- Aggregate: $11,000 = FBAR required
Even if Account C had $2,000 for only one day while the other accounts were low, if the combined maximum ever exceeded $10,000, you must file.
For complete requirements, see our FBAR Filing Guide.
Financial Interest: When You Own Accounts
You have a financial interest in an account if:
- The account is in your name (sole or joint)
- You’re the owner of record or holder of legal title
- You own more than 50% of a corporation that owns the account
- You’re a partner in a partnership that owns the account
- You’re a beneficiary or trustee of a trust that owns the account
- Another person acts as your agent regarding the account
Key point: You don’t need to have personal access to the account. Owning through an entity you control creates financial interest.
Signature Authority: When You Control But Don’t Own
Signature authority means you have authority to control the disposition of assets in an account, even if you don’t own it.
You have signature authority if you can:
- Write checks on the account
- Transfer funds from the account
- Direct how money is spent
- Control the account through power of attorney
Common examples:
- Corporate officers with check-signing authority on foreign company accounts
- Trustees of foreign trusts
- Power of attorney holders for family members
- Authorized signers on employer’s foreign accounts
Special deadline for signature authority only: If you have ONLY signature authority (no financial interest), your deadline extends to April 15 of the following year. For 2025 accounts, that means April 15, 2027.
Accounts That Must Be Reported
| Account Type | Reportable? |
|---|---|
| Foreign bank accounts (checking, savings) | Yes |
| Foreign securities accounts | Yes |
| Foreign mutual funds | Yes |
| Foreign retirement accounts | Usually yes |
| Foreign life insurance (with cash value) | Yes |
| Foreign trust accounts you benefit from | Usually yes |
| Foreign entity accounts you control | Yes |
| Accounts at US branch of foreign bank | No |
| Foreign branch of US bank | Yes |
Note on pensions: Most foreign pension plans are reportable. This includes Australian Super, Canadian RRSP, UK pension schemes, and employer pension plans in foreign countries. Some treaty-qualified plans have special rules.
Accounts Exempt from FBAR
| Account Type | Why Exempt |
|---|---|
| U.S. branch of foreign bank | Under U.S. jurisdiction |
| Government accounts (official capacity) | Specific exemption |
| Correspondent/nostro accounts | Banking exemption |
| IRA-owned accounts | Reported on Form 8938 instead |
| Tax-qualified retirement plan accounts | Different reporting rules |
Common confusion: Accounts at the U.S. branch of a foreign bank (like HSBC USA) are NOT reportable on FBAR. But accounts at the foreign branch of a U.S. bank (like Citibank UK) ARE reportable.
Joint Account Rules
When you hold a joint account with someone else:
- Each owner reports the full account value on their FBAR
- Both owners have filing obligations (if both are U.S. persons)
- The same account appears on both FBARs
For married couples:
- If filing jointly, you can file one FBAR for both spouses
- One spouse can sign for both if the other spouse consents
- Both spouses must be U.S. persons
For deadline information, see FBAR Deadline.
Business Account Rules
| Business Type | Who Files |
|---|---|
| Sole proprietorship | Owner files on personal FBAR |
| Partnership/LLC | Entity files, partners may also file |
| Corporation | Corporation files separate FBAR |
| Trust | Trustee files for trust |
Officers with signature authority: If you’re an officer of a company with check-signing authority over foreign accounts, you may need to report those accounts on your personal FBAR under signature authority rules.
For foreign partnerships, see our Form 8865 Guide.
Foreign Pension Plans
Foreign pension plans generally require FBAR reporting:
Reportable pension types:
- Employer pension plans in foreign countries
- Australian Superannuation
- Canadian RRSP, RRIF, TFSA
- UK pension schemes (workplace and private)
- EU member state pensions
- Hong Kong MPF
How to report:
- Report maximum value during the year
- Convert to USD using Treasury year-end rate
- Include on FBAR even if you can’t access the funds
See FBAR Exchange Rates for currency conversion.
Cryptocurrency and FBAR
Current rule (2026): Cryptocurrency held on foreign exchanges is NOT reportable on FBAR.
However:
- FinCEN has authority to require reporting
- Proposed regulations would include virtual currency
- Monitor for changes
- Form 8938 may require crypto reporting (different rules)
For FBAR vs Form 8938 rules, see FBAR vs Form 8938 Comparison.
Special Situations
Green Card Holders
- FBAR required from your first year of U.S. residency
- Many green card holders don’t know about this requirement
- Delinquent procedures can help catch up
- See Delinquent FBAR Filing
Dual Citizens
- FBAR required as a U.S. citizen
- Regardless of where you live
- Regardless of your other citizenship
- Many dual citizens living abroad are unaware
Expats Living Abroad
- Same rules as U.S. residents
- Accounts in your country of residence are still reportable
- Local bank account + foreign to you = reportable
- Consider FBAR Filing Services
New U.S. Residents
- FBAR required once you become a U.S. person
- Prior years as a nonresident don’t require FBAR
- Start filing for your first year of residency
Quick Self-Assessment
Answer these three questions:
- Are you a U.S. person? (citizen, resident, domestic entity)
- Do you have any foreign financial accounts?
- Did the aggregate maximum value exceed $10,000 at any point?
If YES to all three → You must file FBAR
For penalty information, see FBAR Penalties & Relief.
Frequently Asked Questions
Who is required to file an FBAR?
U.S. persons (citizens, residents, and domestic entities) who have a financial interest in or signature authority over foreign financial accounts must file FBAR if the aggregate value exceeds $10,000 at any time during the calendar year.
What is a U.S. person for FBAR purposes?
A U.S. person includes U.S. citizens, resident aliens (green card holders), persons meeting the substantial presence test, domestic trusts and estates, and entities created or organized in the United States.
Do green card holders need to file FBAR?
Yes. Green card holders are U.S. persons for FBAR purposes and must file if they meet the $10,000 aggregate threshold, regardless of where they live.
What accounts must be reported on FBAR?
Foreign bank accounts, securities accounts, mutual funds, certain retirement accounts, life insurance with cash value, and other financial accounts held at foreign financial institutions.
Do I need to file FBAR for a joint account?
Yes. Each U.S. person with a financial interest in a joint account must report it. The full value is reported by each owner. Married couples filing jointly may file one combined FBAR.
Are foreign retirement accounts reportable on FBAR?
Generally yes. Most foreign pension plans, including Australian Super, Canadian RRSP, and UK pensions, require FBAR reporting. Report the maximum value during the year.
Does signature authority require FBAR filing?
Yes. If you have authority to control assets in a foreign account (even without ownership), you may have FBAR filing obligations under signature authority rules.
Do I file FBAR if I have no income from the account?
Yes. FBAR is required based on account ownership and value, not income. You file even if the account earned no interest and you owe no U.S. tax on it.
Related FBAR Resources
- Complete FBAR Filing Guide
- FBAR Deadline
- FBAR Penalties & Relief
- FBAR vs Form 8938 Comparison
- Delinquent FBAR Filing Procedures
- FBAR Exchange Rates Guide
- Form 1040-NR Guide
- All International Tax Services
Not Sure If You Need to File FBAR?
We can analyze your situation and determine your requirements. Get an upfront estimate before we start.
View FBAR Filing Services | Schedule a Consultation
Official Resources: