If you’re a U.S. citizen or green card holder living abroad, your biggest tax concern might be filing your annual U.S. tax return. But there’s another crucial form many expats forget and ignoring it can lead to massive penalties. It’s the FBAR, and failing to file it properly could cost you $10,000 or more per violation. Even if you don’t owe any taxes.
In this guide, we’ll break down FBAR filing for expats: what it is, who needs to file, and how to stay compliant and penalty-free.
What Is the FBAR?
FBAR stands for Foreign Bank Account Report, officially known as FinCEN Form 114. It’s not part of your regular IRS tax return. Instead, it’s a separate filing that goes to the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). The purpose? To prevent tax evasion through offshore accounts.
Who Needs to File an FBAR?
You must file an FBAR if you are a United States person (including citizens, green card holders, and residents) and:
- You have a financial interest in or signature authority over one or more foreign financial accounts,
- And the total combined value of those accounts exceeds $10,000 at any time during the calendar year.
This includes:
- Checking and savings accounts
- Investment or brokerage accounts
- Foreign pension accounts
- Certain cryptocurrency exchanges (in some cases)
- Joint accounts, even if your spouse isn’t American
For expats, this means if you live overseas and use a local bank, even just to pay bills or receive your paycheck, you likely have to file the FBAR.
When Is the FBAR Due?
The FBAR is due on April 15, with an automatic extension to October 15 — no need to file a separate extension request.
Unlike your tax return, FinCEN Form 114 must be filed online through the BSA E-Filing System — not with the IRS.
What Happens If You Don’t File?
The penalties for not filing an FBAR can be severe:
- Non-willful violation: Up to $10,000 per violation
- Willful violation: The greater of $100,000 or 50% of the account balance
You could still be fined even if you didn’t know about the FBAR requirement. That’s why FBAR filing for expats is so important — and why working with a CPA is often the safest route.
What If You Forgot to File?
If you’ve missed past FBARs, don’t panic! There are IRS programs like the Streamlined Filing Compliance Procedures that help eligible expats catch up without facing harsh penalties. The key is to act before the IRS contacts you. Voluntary disclosure is usually more favorable.
FBAR vs FATCA: What’s the Difference?
Both FBAR and FATCA involve reporting foreign accounts, but they’re different:
| FBAR (FinCEN Form 114) | FATCA (Form 8938) |
| Filed with FinCEN | Filed with the IRS |
| $10,000 reporting threshold (total across accounts) | Higher thresholds (starting at $50,000 for U.S. residents) |
| Includes signature authority accounts | Typically excludes accounts without ownership interest |
| Penalties can be more severe | Penalties are still serious but less extreme |
Some expats must file both forms depending on their circumstances.
Tips for Expats Filing FBA
- Track account balances: Use year-end and high-balance statements for accuracy.
- Report all accounts: Even if you closed them during the year or shared them with a non-U.S. person.
- Use the correct filing system: The BSA E-Filing System, not IRS Free File.
- Keep records: You should retain documentation for at least five years.
FBAR filing for expats isn’t optional, and it’s one of the most common areas where Americans abroad get into trouble with the IRS. Even if your taxes are simple, failing to report your foreign accounts can result in complicated and costly consequences.
Need Help With FBAR Filing?
At Zaouk CPA, we specialize in helping U.S. expats worldwide comply with FBAR, FATCA, and all their international tax obligations. Among many other financial and tax services. So whether you need to file for the first time or catch up on missed years, we make it easy and stress-free. Book a consultation today and get expert support with your FBAR and expat tax filing.
