Tax
FBAR
Also known as: Foreign Bank Account Report, FinCEN Form 114, Report of Foreign Bank and Financial Accounts
Quick answer
FBAR pre-dates FATCA by 40 years (originating in the 1970 Bank Secrecy Act) but became dramatically more enforced after FATCA cross-referencing began in 2014. The reporting trigger is the aggregate balance across ALL foreign financial accounts on which the US person has signature authority or financial interest exceeding $10,000 USD-equivalent at any single point during the calendar year — even for one day. This is a low threshold compared to FATCA's $200,000+ for expat individuals.
Reportable accounts include: foreign bank accounts (checking, savings, time deposits), foreign brokerage and securities accounts, foreign mutual funds, foreign pension accounts (a frequent surprise for expats), and certain foreign life insurance policies with cash value. Accounts held jointly with a non-US-person spouse must still be reported if the US person has signature authority. Pre-paid cards, gift cards, and crypto wallets are currently not reportable, though the rules around digital-asset accounts are evolving.
Filing: electronic only via the BSA E-Filing System. Due date is 15 April, with an automatic extension to 15 October. No physical paper option. The form requests for each account: institution name and address, account number, account type, maximum value during the year, and ownership structure.
Non-filing penalties: • Non-wilful: $10,000 per year (per Bittner v. United States, 2023, the cap is per FBAR not per account — a meaningful taxpayer victory). • Wilful: greater of $100,000 or 50% of the account balance per year. Criminal prosecution possible in egregious cases.
The Streamlined Filing Compliance Procedure remains the standard remedy for non-wilful non-filers, requiring 6 years of back FBARs plus 3 years of back tax returns.
Sources
Last factual review: 2026-05-08.
Related terms
FATCA
FATCA is a 2010 US law requiring foreign financial institutions to report accounts held by US persons to the IRS, and US persons themselves to disclose foreign financial assets above threshold amounts on Form 8938. Thresholds for individuals living abroad start at $200,000 (single) / $400,000 (joint) at year-end. FATCA penalties for non-disclosure are severe: $10,000 minimum per failure, doubling every 30 days up to $50,000.
IRS Streamlined Filing Compliance Procedure
The IRS Streamlined Filing Compliance Procedure is the standard remedial pathway for US persons who failed to file FBARs, Form 8938, or income tax returns reporting foreign income — provided their non-compliance was non-wilful. The Streamlined Foreign Offshore Procedure (SFOP), for taxpayers living abroad, requires 3 years of amended/late tax returns + 6 years of FBARs + a non-wilfulness statement. Penalty: zero on SFOP if non-wilfulness is established.
FEIE (Foreign Earned Income Exclusion)
FEIE lets US citizens and resident aliens exclude up to $132,900 (2026) of foreign-earned income from US federal income tax — but not from Social Security/self-employment tax. To qualify, the taxpayer must meet either the Bona Fide Residence Test (full-year tax residence in a foreign country) or the Physical Presence Test (330 full days abroad in any 12-month period). Claimed on IRS Form 2555 attached to Form 1040.
Deeper guides
FBAR & FATCA 2026: Complete Compliance Guide for US Expats (Penalties, Deadlines, Banking)
Every US person with $10,000+ in foreign accounts must file FBAR. Penalties up to $165,353 for willful violations. FATCA Form 8938 thresholds, FATCA-friendly banks by country, amnesty programs for late filers, and the 2026 enforcement landscape.
Expat Banking 2026: Which US Banks Won't Close Your Account Abroad?
Schwab and Fidelity won't close your account abroad — most US banks will. Plus: Wise vs banks (0.5% vs 3-5%), opening accounts in 20 countries, and FBAR/FATCA filing.
FEIE vs. Foreign Tax Credit in 2026: Which Saves You More? ($132,900 Exclusion)
2026 FEIE raised to $132,900. Compare the Foreign Earned Income Exclusion and Foreign Tax Credit with worked examples by income level. Includes FBAR and FATCA requirements.
Expat Taxes in 2026: What Americans Living Abroad Need to Know
FBAR, FEIE, tax treaties, and the 2026 basics of US tax obligations for Americans living overseas.
ImmigrationOS: How Palantir's $30M ICE Contract Changes Visa Compliance in 2026
ICE awarded Palantir a $30M April 2025 contract to build ImmigrationOS — a unified platform joining IRS, SSA, DMV, passport, and license-plate-reader data. Prototype delivered Sept 25 2025; contract runs through Sept 2027. Practical implications for US citizens abroad, green card holders, H-1B/NIV holders, and N-400 applicants. Five-item 2026 compliance checklist.