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Service · FBAR and FATCA · updated 28 August 2026

If your foreign accounts touched $10,000, you file an FBAR — and you can file it free.

FBAR (FinCEN Form 114) is due when your foreign accounts together passed $10,000 at any point in the year. FinCEN's own system files it at no cost. FATCA (Form 8938) is separate, has higher thresholds, and travels with the tax return.

Book a 20-minute call FBAR-Only Filing — $125

FBAR and FATCA are not the same form

FBAR — FinCEN Form 114FATCA — Form 8938
Filed withFinCEN, separately from the returnThe IRS, attached to Form 1040
Threshold$10,000 aggregate, at any point in the year$200,000 at year end for a single filer abroad
CoversForeign bank and financial accountsForeign financial assets, including some non-account assets
Non-willful penalty$16,536$10,000
Cost to file yourselfFree through FinCENPart of the return
Sources: 31 CFR 1010.350 and 1010.821; IRC §6038D; IRS Publication 54. Thresholds shown for a single filer living abroad — married and joint thresholds differ. Checked 28 August 2026.

The honest version: filing the FBAR is the easy part, and you can do it yourself in twenty minutes. What people get wrong is which accounts count — a joint account with a spouse, a pension you cannot touch, a company account you sign on — and whether Form 8938 was also required. That review is what the fee buys.

The part people get wrong

Which accounts count, and the six that get missed.

The threshold is the total of the highest balance in each account, across every account, at any point in the year — not the year-end balance, and not per account.

A joint account with a spouseCounts in full for both of you, even when only one name is on the salary going into it.
An account you only sign onSignature authority over an employer or church account is reportable, with no money of your own in it.
A foreign pension or provident fundOften reportable, depending on your interest in the account. One of the two questions I check on every return.
A brokerage account held abroadA financial account for FBAR, and frequently a Form 8938 asset as well.
A company account you sign forYour employer’s account is theirs; your authority over it is still yours to report.
An account you closed mid-yearA closed account still counts, at the highest balance it held before it closed.

The non-willful penalty for a missed FBAR is $16,536. That figure is why the review exists, not why you should be frightened — almost every case I see is a person who simply did not know a provident fund was an account.

Questions I get about FBAR and FATCA

Do I count the highest balance or the year-end balance?

The highest balance in the year, for each account, converted at the Treasury year-end rate. The threshold is the total across all accounts, not per account.

I have missed FBARs for several years. What now?

Late FBARs now travel with a Streamlined submission or a reasonable-cause statement — the IRS terminated the Delinquent FBAR Submission Procedures around 1 July 2026.

Does a foreign pension go on the FBAR?

Often yes, and the answer turns on whether you have a financial interest in or signature authority over the account. It is one of the two questions I check on every return.

If I can file it free, why would I pay you $125?

For most people, you should not. Pay for the review when you are unsure which accounts count or whether Form 8938 was also required — that judgement is the fee, not the typing.

Do I file an FBAR if I owe no tax?

Yes. The FBAR is a report, not a tax. It is due whenever the accounts crossed $10,000 in aggregate, whatever your income was.

Related

Asset → form router →What you hold, and which form reports it.Catch-up filing (Streamlined) →$1,395 — three returns, six FBARs, Form 14653.File your own FBAR at FinCEN →Free, and the right answer for some people.

Not sure which of your accounts count?

That is the twenty-minute call. If the answer is that you can file it yourself for nothing, you will hear that.

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