FBAR: Do I Need to Report My Foreign Bank Accounts?

What is FBAR?

FBAR stands for Foreign Bank Account Report — officially FinCEN Form 114. It's a disclosure requirement under the Bank Secrecy Act that requires U.S. persons to report foreign financial accounts if the combined maximum value exceeded $10,000 at any point during the calendar year.

FBAR is not a tax — you don't pay anything when you file it. It's a disclosure, telling the U.S. government that you have accounts abroad. But the penalties for not filing are severe, and many Chinese immigrant families with accounts in Taiwan or China are unaware this requirement applies to them.

⚠️ This surprises most new immigrants from China and Taiwan

If you moved to the U.S. and still have bank accounts, investment accounts, or other financial accounts in Taiwan or China — and those accounts combined exceeded $10,000 at any point in the year — you are required to file an FBAR. This applies even if the accounts generated no income and even if you owe no U.S. tax on them.

Who must file FBAR?

A "U.S. person" with foreign financial accounts exceeding the threshold must file. U.S. persons include:

U.S. citizens (including dual citizens)
Green card holders (lawful permanent residents)
Resident aliens (those who pass the Substantial Presence Test)
U.S. corporations, partnerships, LLCs, trusts, and estates

Your status	Must file FBAR?	Note
U.S. citizen	✅ Yes (if threshold met)	Regardless of where you live
Green card holder	✅ Yes (if threshold met)	Even if you spent most of the year abroad
Resident alien (passed SPT)	✅ Yes (if threshold met)	Includes most H-1B holders after enough time in U.S.
Nonresident alien (F-1 first 5 years)	❌ Generally no	Not a U.S. person for FBAR purposes
J-1 teacher or trainee (generally first 2 years)	❌ Generally no	Not a U.S. person for FBAR purposes

The $10,000 threshold: how it works

The threshold is $10,000 combined across all foreign accounts at any single point during the year — not the year-end balance, not the average balance.

Examples:

On June 30, Account A (Taiwan bank) held $8,000 and Account B (China brokerage) held $4,000 — a combined $12,000 on the same day.

✅ Must file FBAR — reports BOTH accounts

Single Taiwan bank account. Max balance at any point: $9,500.

❌ No FBAR required — never exceeded $10,000

Account balance was $12,000 in January, then fell to $3,000 for the rest of the year.

✅ Must file FBAR — $12,000 exceeded threshold in January

What accounts must be reported?

FBAR covers a broad range of foreign financial accounts:

Must report ✅

·Bank accounts (savings, checking, fixed deposits)

·Brokerage and investment accounts

·Mutual fund accounts

·Pension and retirement accounts

·Life insurance policies with cash value

·Accounts where you have signature authority (even if not your money)

Generally not reported ❌

·Real estate held directly (not through a foreign entity)

·Precious metals held directly

·Foreign currency held personally (not in an account)

·Social insurance programs (like Taiwan's labor insurance)

·Unsecured loans to foreign parties

How to file FBAR

File electronically at the BSA E-Filing System: bsaefiling.fincen.treas.gov. This is separate from IRS.gov — FBAR is not filed with your tax return.
Deadline: April 15, with an automatic extension to October 15. No need to request the extension — it's automatic.
What you report: For each foreign account — the bank name and address, account number, account type, maximum value during the year (converted to USD using the December 31 exchange rate or Treasury rate).
No tax payment: FBAR is disclosure only. You pay nothing when you file it.

	FBAR (FinCEN 114)	FATCA (Form 8938)
Filed with	FinCEN (bsaefiling.fincen.treas.gov)	IRS (with your tax return)
Threshold — Single	$10,000 combined at any point	$50,000 year-end or $75,000 at any point
Threshold — MFJ	$10,000 combined at any point	$100,000 year-end or $150,000 at any point
Deadline	April 15 (auto-extended to Oct 15)	Tax return due date (April 15 + extensions)
If both apply	File FBAR	Also file Form 8938 — they are not interchangeable

✅ If you have missed FBAR filings from prior years

Don't ignore it. The IRS Streamlined Filing Procedures allow non-willful late filers to come forward voluntarily with significantly reduced penalties — sometimes penalty-free for taxpayers living abroad. Voluntarily disclosing almost always produces better outcomes than being discovered. Consult a tax attorney or CPA experienced in international tax compliance before filing late FBARs.

Frequently asked questions

Yes. The FBAR filing requirement is triggered by the account balance alone — not by any income generated. If your combined foreign accounts exceeded $10,000 at any point during the year, you must file regardless of whether the accounts generated any income or return.

Combined. The test is whether the aggregate value of all foreign financial accounts you own or have signature authority over exceeded $10,000 at any time during the year. If it did, all accounts must be reported — even accounts that individually never exceeded $10,000.

Yes, if you have signature authority or financial interest in the account. Being a named account holder — even as a convenience signer — typically triggers FBAR reporting if the combined threshold is met. You should report the account on your FBAR even if you never used or benefited from it.

Penalties can be severe. Title 31 of the U.S. Code sets civil penalties for non-willful and willful violations (willful penalties are far higher), and criminal penalties may also apply. The civil penalty maximums are adjusted for inflation every year — figures often quoted online, such as $10,000 for non-willful violations or the greater of $100,000 or 50% of the account balance for willful violations, were the maximums for penalties assessed before August 1, 2016, not today's amounts. Whether the IRS asserts a penalty depends on the facts and circumstances. The IRS has Voluntary Disclosure programs for late filers that can significantly reduce penalties — consult a tax professional if you have unfiled FBARs.

Both require reporting foreign accounts, but they're different requirements with different thresholds. FBAR (FinCEN 114): $10,000 threshold, filed separately with FinCEN (not IRS). FATCA/Form 8938: higher thresholds ($50,000 for single filers, $100,000 for MFJ), filed with your tax return with the IRS. Many people with foreign accounts must file both. They are not interchangeable — filing one does not satisfy the other.

The IRS has provided limited specific guidance on digital payment accounts like WeChat Pay and Alipay. The general principle is that if these are considered "financial accounts" under foreign financial institutions, significant balances may be reportable. Given the evolving guidance, if you maintain substantial balances in these platforms, consult a CPA familiar with international tax reporting.

Don't ignore it. The IRS has two main programs for late FBAR filers: the Streamlined Filing Procedures (for non-willful violations — reduced penalties or penalty-free for offshore residents) and the Delinquent FBAR Submission Procedures (for late filers with no other issues). Voluntarily coming forward almost always results in better outcomes than being caught. Consult a tax attorney or CPA before filing late FBARs.

FBAR: do I need to report my foreign bank accounts?

What is FBAR?

Who must file FBAR?

The $10,000 threshold: how it works

What accounts must be reported?

Must report ✅

Generally not reported ❌

How to file FBAR

Frequently asked questions

Official sources

Related guides

Do I need to file an FBAR? How the $10,000 rule really works

New immigrant complete tax guide

Crypto taxes explained

Am I a U.S. tax resident?