Which foreign financial accounts are reportable on an FBAR?
Short answer
FBAR reporting can cover more than ordinary bank accounts. FinCEN’s definition includes foreign bank accounts and securities/brokerage accounts, and can also include certain commodity futures or options accounts, cash-value insurance or annuity policies, and shares in certain mutual funds or similar pooled funds.Source 1Source 2
The account generally must be located outside the United States. The location of the financial institution or branch maintaining the account matters more than the nationality of the institution.Source 1Source 2 Once you know which accounts are reportable, their values feed into the $10,000 aggregate threshold.
What makes an account “foreign”?
A foreign financial account is generally a financial account located outside the United States.Source 1 FinCEN gives two useful branch examples:
Branch location
The institution’s brand or home country is therefore not enough by itself; the location of the account matters.
What is not automatically a “financial account”?
IRS examination guidance distinguishes an account from assets held directly. It states that stocks, bonds or similar financial instruments held directly by the person are not themselves financial accounts, and it also lists real estate or an account holding solely real estate as outside the financial-account definition.Source 3
This does not mean every structure holding investments or real estate is automatically outside FBAR. If an asset is held through a foreign bank, brokerage, fund, trust or other financial arrangement, the account or arrangement itself may need separate analysis.
Common reportable account categories
| Account type | Typical FBAR treatment | Practical note |
|---|---|---|
| Foreign checking/current account | Commonly reportable | Includes demand/checking accounts maintained outside the United States.Source 1Source 2 |
| Foreign savings or time-deposit account | Commonly reportable | Includes savings, deposit and time-deposit accounts.Source 1Source 2 |
| Foreign brokerage/securities account | Commonly reportable | An account with a person engaged in buying, selling, holding or trading securities can qualify.Source 1Source 3 |
| Mutual fund or similar pooled fund | Can be reportable | FinCEN includes qualifying funds available to the general public with regular NAV determination and regular redemptions.Source 1Source 3 |
| Cash-value life insurance or annuity | Can be reportable | The relevant category is an insurance or annuity policy with a cash value.Source 1Source 3 |
| Commodity futures/options account | Can be reportable | Covered where the account is maintained with the relevant broker/dealer described by the rules.Source 1Source 3 |
What about joint accounts?
A financial account owned jointly by two or more persons can be a joint account for FBAR purposes.Source 1 Whether each owner must file, how the account is reported and the special spouse/Form 114a rule are covered in the dedicated joint-account and spouse guidance.
What about a foreign pension or retirement arrangement?
Do not use a one-line rule for every foreign pension. Some foreign pension or retirement arrangements can involve reportable financial accounts, while the regulations also contain specific exceptions for certain U.S. tax-qualified retirement plans and IRAs.Source 1Source 3 The legal and operational structure matters, so foreign pensions belong in dedicated guidance rather than being classified solely by their label.
What about an employer’s foreign account?
Ownership is not the only route into FBAR analysis. An individual can potentially have an FBAR filing issue through signature or other authority over an employer’s foreign account even without owning it.Source 1 Whether that authority exists depends on the facts, including whether the individual can control the disposition of funds through communication with the financial institution.Source 1 See signature or other authority.
Does the account need to earn income?
No. IRS guidance states that whether the account produced taxable income does not determine whether it is a foreign financial account for FBAR purposes.Source 4 FBAR reporting and income-tax reporting are related but separate questions.
Examples
Example
Dutch current account
Example
Swiss brokerage account
Example
Foreign cash-value life insurance
Example
Directly owned foreign real estate
Direct ownership of foreign real estate is not, by itself, a financial account under the IRS examination guidance.Source 3
Related questions
Is an account at a foreign branch of a U.S. bank foreign for FBAR purposes?
Yes. FinCEN’s instructions specifically use an account at a branch of a U.S. bank physically located outside the United States as an example of a foreign financial account.Source 1
Is an account at a U.S. branch of a foreign bank foreign for FBAR purposes?
No, not merely because the bank is foreign. FinCEN’s instructions state that an account maintained at a branch physically located in the United States is not a foreign financial account.Source 1
Are foreign stocks or bonds automatically FBAR accounts?
Not when they are held directly merely as assets. IRS examination guidance says directly held stocks, bonds and similar financial instruments are not themselves financial accounts. A foreign brokerage or securities account holding them can be a different matter.Source 3
Does a closed foreign account still matter?
The FBAR regulation requires a U.S. person with a financial interest in, or signature or other authority over, a foreign financial account to report that relationship “for each year in which such relationship exists.”Source 2 The value reported for each account is its maximum value during the calendar year being reported.Source 1
Are foreign pensions always reportable?
No single rule safely covers every foreign pension. The answer depends on the structure and the type of underlying account or arrangement. Use dedicated pension guidance or professional review for uncertain cases.
Does an account have to earn interest or investment income to be reportable?
No. The IRS expressly says that whether the account produced taxable income does not determine whether it is a foreign financial account for FBAR purposes.Source 4
Next pages
Sources
Official sources used for this page.
Source 1: FinCEN, FinCEN Report of Foreign Bank and Financial Accounts (FBAR) Electronic Filing Requirements (opens in a new tab)
Definitions of financial account, foreign financial account, joint account, signature authority and listed exceptions.
bsaefiling.fincen.govChecked Source updated Back to text
Source 2: eCFR, 31 CFR § 1010.350 (opens in a new tab)
Regulatory definitions and FBAR reporting requirements.
ecfr.govChecked Back to text
Source 3: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)
Financial-account categories, exclusions and account valuation.
irs.govChecked Source updated Back to text
Source 4: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)
Core account examples and statement that taxable income does not determine account status.
irs.govChecked Back to text