The Foreign Bank Account Report (FBAR)

A guide to reporting your

Foreign Bank & Financial Accounts.

Everything you need to know to e-file your FBAR

What is the FBAR filing requirement?


  • Every year, under the law known as the Bank Secrecy Act, you must report certain foreign financial accounts, such as bank accounts, brokerage accounts, pension funds, mutual funds, unit trusts, or other types of financial accounts, to the Treasury Department, and keep certain records of those accounts.
  • Generally, an account at a financial institution located outside the United States is a foreign financial account. Whether the account produced taxable income has no effect on whether the account is a “foreign financial account” for FBAR purposes.
  • You report the accounts by filing a Report of Foreign Bank and Financial Accounts (FBAR) on FinCEN Form 114.
  • FinCEN stands for Financial Crimes Enforcement Network. FinCEN is part of the Treasury Department, but separate from the IRS.




Do I need to complete an FBAR?


  • Under the Bank Secrecy Act, each United States person must file a Report of Foreign Bank and Financial Accounts (FBAR), if:
  1. The person has a financial interest in, or signature authority (or other authority that is comparable to signature authority) over one or more accounts in a foreign country and;

  2. The aggregate (total) value of all foreign financial accounts exceeds $10,000 at any time during the calendar year. This is determined by using the highest combined foreign currency balances of all accounts during the year converted into USD using the exchange rate on 12/31 of the year.
CAUTION! If the total maximum value of all accounts exceeds $10,000 at any time during the year, the FBAR must be filed even if none of the accounts individually exceeded $10,000. For example, Peter has 3 bank accounts. On June 25, 2019 he had EUR 5,000 in the first account, EUR 3,000 in the second account, and EUR 1,000 in the third account. The total is EUR 9,000. Using the Treasury rate of 1 USD = .8900 EUR, the total value in USD is $10,112. Peter must file an FBAR and report the maximum value of each account during the year. The maximum value of each account reported could have occurred on any day of the year.

  • A person who holds a foreign financial account may have a reporting obligation even though the account produces no taxable income. Checking the appropriate block on FBAR-related federal income tax return questions (found on Form 1040 of Schedule B) and filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts FBAR, satisfies the account holder's reporting obligation.
  • Children. Generally, a child is responsible for filing their own FBAR. If a child can’t file their own FBAR for any reason, such as age, the child's parent or guardian must file it for them. If the child can’t sign their FBAR, a parent or guardian must sign it.




When is the FBAR due date?


  • The FBAR is not filed with the filer's Federal income tax return. The due date for filing an FBAR is April 15. However, an automatic extension to October 15 is granted without any action on the part of the filer.
  • Therefore, the FBAR must be received by FinCEN on or before October 15 of the following year in order to be considered timely filed.
  • On late filed FBARs you are required to provide a reason why the report is being filed late. FinCEN helpfully includes a list of reasons in a dropdown box on the Form.




Is it possible to paper file my FBAR?


  • No. FBARs may no longer be paper filed. This includes prior year reports.
  • If you want to paper-file your FBAR, you must call FinCEN’s Regulatory Helpline to request an exemption from e-filing. If FinCEN approves your request, FinCEN will send you the paper FBAR form to complete and mail to the IRS at the address in the form’s instructions. IRS will not accept paper-filings on TD F 90-22.1 (obsolete) or a printed FinCEN Form 114 (for e-filing only).




Where and how do I E-file my FBAR?


  • FBARs must be E-filed. In order to prepare and E-file the FBAR you can access by clicking the link below to the BSA E-Filing System, and then follow the instructions. Essentially a filer downloads the form, completes it, signs it electronically, and then submits it to FinCEN.
  • It is also possible to file directly online without downloading the Form.

  • A filer may include joint accounts on the form.

  • Please keep the submission confirmation receipt for your files.




What if all my accounts are jointly owned with my spouse?


  • You don’t need to file an FBAR for the calendar year if:
  1. All your foreign financial accounts are jointly-owned with your spouse and;

  2. You completed and signed FinCEN Form 114a authorizing your spouse to file on your behalf, and your spouse reports the jointly-owned accounts on a timely-filed, signed FBAR.

  • Otherwise, both spouses must file separate FBARs, and each spouse must report the entire value of the jointly-owned accounts.




Keeping Records


  • You must keep records for each account you are required to report on an FBAR as follows:
  1. Name on the account,

  2. Account number,

  3. Name and address of the foreign bank,

  4. Type of account, and

  5. Maximum value during the year.

  • The law doesn’t specify the type of document to keep with this information; it can be bank statements or a copy of a filed FBAR, for example, if they have all the information.
  • You must keep these records for five years from the due date of the FBAR.




What Currency Exchange Rate should I use on my FBAR?


  • The highest foreign currency balance of each account held during the year should be exchanged using the Department of Treasury’s exchange rate on 12/31 of the year.
  • For your convenience, these are the main Treasury December 31, 2019 exchange rates: 1 USD = AUD 1.4250, CAD 1.3000, EUR .8900, GBP .7580, JPY 108.53, SGD 1.3450, SFR .9660
  • Click the link below for a complete list of the Treasury Reporting Rates of Exchange as of December 31, 2019:

Exchange Rates

  • For example: During 2019, Peter’s highest balance in his UK Barcwest Bank account is £12,351. Per the Treasury Reporting rates, United Kingdom Pound to one US Dollar is: 0.7580. Peter will therefore include £12,351/0.7580 = $16,294 in his FBAR as the maximum USD value of his Barcwest Bank account.




How do I amend my FBAR?


  • If you filed your FBAR through the BSA E-Filing website and you need to amend your FBAR to correct any information, you will need to fill out a new FBAR completely (i.e report ALL the accounts again) and check the Amend box in Item 1.
  • You will need to provide your Prior Report BSA Identifier after selecting the Amend box. Your Prior Report BSA Identifier was provided to you either through email or via the BSA E-Filing System’s secure messaging feature.
  • If your Prior Report BSA Identifier is not known, please enter 00000000000000 in the Prior Report BSA Identifier field.
  • Once completed, submit following the instructions on the BSA E-filing website in the usual way




Potential Penalties


  • Individuals may be subject to civil monetary penalties and/or criminal penalties for FBAR reporting and/or recordkeeping violations. Assertion of penalties depends on facts and circumstances. Current maximums are as follows:




Useful Information


  • The IRS FBAR Reference Guide can be found here:

IRS FBAR GUIDE





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