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FBAR Filing Requirements 2025: Complete Guide to Foreign Bank Account Reporting

Latest Facts & News

The 2025 FBAR deadline remains April 15, 2025, with an automatic extension to October 15, 2025.
The $10,000 threshold for the combined value of all foreign accounts triggers the filing requirement.
Electronic filing is mandatory through the BSA E-Filing system; no paper submissions are accepted.
IRS increased enforcement with over 800,000 FBAR filings processed annually.

Foreign account reporting never starts with a form. It starts with small details, balances that cross a limit, shared accounts that aren’t fully understood, or signatory rights that seem minor. In 2025, the filing rules remain the same, but enforcement continues to grow. Read along to see how FBAR filing requirements apply and what needs to be reported before the deadline.

What Are FBAR Filing Requirements?

If you are a U.S. person and have money outside the United States, you might have to file an FBAR.

Who Is Required to File FBAR: Complete Eligibility Guide

You must file an FBAR if all these are true:

You are a U.S. person (citizen, green card holder, resident, or U.S.-registered business).
You have one or more foreign bank or financial accounts.
The combined value of all foreign accounts exceeded $10,000 at any time during the year.

Important Points to Remember

Include accounts you fully own, share, or have the right to benefit from.
Include accounts where you have signature authority, even if you do not own the funds.
Account types include checking, savings, brokerage, retirement, and pension accounts held outside the U.S.

Understanding the Bank Secrecy Act Foundation

The Bank Secrecy Act is the law behind the FBAR. It was created to stop hiding money, tax evasion, and money laundering. Key points:

U.S. persons with certain foreign accounts must report them.
The Financial Crimes Enforcement Network (FinCEN) collects and protects this data.
This law prevents offshore accounts from hiding money from the government.

FBAR vs. Tax Return Filing

FBAR and tax returns are separate filings:

FBAR: Report to FinCEN about foreign bank accounts. Filed online, free of charge.
Tax return: Report income and taxes to the IRS.

You file FBAR separately from your tax return. Both filings help show compliance with U.S. laws.

FBAR Reporting Requirements: What Accounts Must Be Reported

Reportable Foreign Financial Accounts

Checking accounts
Savings accounts
Bank deposit accounts
Investment or brokerage accounts
Mutual fund accounts
Pension or retirement accounts from foreign jobs
Foreign life insurance or annuity policies with cash value
Accounts in foreign credit unions or cooperative banks

Examples from Other Countries

Canada: RRSP, TFSA, RESP
UK: ISA, premium bonds, foreign work pensions
Australia: Superannuation accounts
India: NRE/NRO accounts, foreign mutual funds

Accounts Exempt from FBAR Reporting

Accounts in U.S. banks
Government or military accounts in the U.S.
Certain employer-handled retirement/pension plans
Accounts held by international organizations or U.S. agencies
Social Security and U.S. government benefit payments

Joint Accounts and Special Situations

Include full value of shared foreign accounts.
Include accounts for elderly parents, children, or businesses if you have control/signature.
Trusts and certain business accounts must be reported if you control or benefit.

FBAR Filing Process: Step-by-Step Guide to FinCEN Form 114

Step 1: Gather All Account Information

Bank/institution name & address
Account number
Highest balance during the year
Type of account
Your full name, address, SSN or ITIN

Step 2: Convert Foreign Currency Balances to U.S. Dollars

Use the Treasury exchange rate for December 31 of the year. Convert highest account balances to USD to see if the $10,000 threshold is exceeded.

Step 3: Access and Use the BSA E-Filing System

File online via BSA E-Filing. Individuals can file without creating an account the first time.

Step 4: Fill Out the Form Carefully

Enter all information accurately. Double-check before submission.

Step 5: Submit the FBAR and Save Confirmation

Submit electronically and save the confirmation page with filing reference number for records.

FBAR Deadlines and Extensions for 2025

FBAR for the 2024 calendar year is due April 15, 2025, with an automatic extension to October 15, 2025. Key points:

Deadlines move to next business day if they fall on a weekend/holiday.
Applies to all U.S. persons, including those abroad.
Separate from tax return extensions.
Late filing without a valid reason may incur penalties.

FBAR Penalties and Consequences of Non-Compliance

Non-Willful FBAR Penalties

Up to $10,000 per year for mistakes. May be waived if reasonable cause is shown.

Willful FBAR Penalties and Criminal Consequences

Greater of $100,000 or 50% of account balance per violation. Possible criminal charges and jail time.

FBAR Penalty Mitigation and Appeals

Penalty relief can be requested for reasonable cause. Appeals can be filed with IRS. Professional guidance from Antony N. Verni is recommended.

FBAR vs. FATCA: Understanding the Differences

Aspect	FBAR (FinCEN Form 114)	FATCA (IRS Form 8938)
Filing Agency	FinCEN	IRS
Form Name	FinCEN Form 114	IRS Form 8938
Filing Threshold	More than $10,000 in foreign bank accounts	$50,000 at year-end or $75,000 anytime (higher if married/abroad)
Non-Willful Penalties	Up to $10,000 per year	Up to $10,000 per failure to file
Willful Penalties	$100,000 or 50% of account balance, whichever is greater	$50,000 per failure to file
Filing Requirements	File if combined foreign bank accounts exceed $10,000	File if foreign assets meet IRS thresholds

Common FBAR Filing Mistakes and How to Avoid Them

Not combining all foreign accounts to check $10,000 threshold
Missing dormant or little-used accounts
Incorrect bank names, addresses, or account numbers
Omitting mutual funds, pensions, or insurance accounts
Late filing or missing deadlines
Confusing FBAR with tax return reporting

Get Expert Help When You Need It Most!

FBAR filing is complex, and mistakes can result in penalties or legal issues. Antony N. Verni has extensive experience helping taxpayers comply with FBAR requirements. Contact him for guidance or consultation.

FAQs

Do I need to file an FBAR if my foreign account balance was only $9,000?

No. You must file only if the total value exceeded $10,000 at any time during the year.

What happens if I discover unreported foreign accounts from previous years?

Report them ASAP. IRS programs allow filing late or updating past reports, which may reduce penalties.

Can I file an FBAR if I don’t have a Social Security Number?

Yes, using an ITIN or special FinCEN rules.

Is there a statute of limitations for FBAR penalties?

No. FBAR penalties have no statute of limitations.

Do cryptocurrency accounts held on foreign exchanges require FBAR reporting?

Yes, if you control or have financial interest in them and combined foreign account value exceeds $10,000.

FBAR Filing Requirements 2025: Deadlines, and Penalties Explained