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FBAR Guard

How to report securities and brokerage account balances on an FBAR

Updated

Short answer

For FBAR purposes, a securities or investment account maintained with a foreign brokerage is generally reported as a financial account. You report the account's greatest value during the calendar year—not a separate FBAR line for every stock or fund inside it. The balance generally includes both the securities and cash held in the account.⁠Source 1⁠Source 2⁠Source 3

A sensible starting point is the broker's periodic portfolio valuation, provided it reasonably reflects the highest total account value during the reporting year. Convert the account's maximum to U.S. dollars using the reporting-year exchange-rate rule, not today's spot rate. Shares you hold directly, outside an account, are not reported on the FBAR.⁠Source 1⁠Source 2⁠Source 3⁠Source 4

First: decide what is an account versus a holding

A securities account with a foreign broker can hold shares, bonds, ETFs, mutual funds and cash. Generally, FinCEN Form 114 records the account's details and maximum value, not each ticker symbol separately. Check the reportable accounts guide for the account-location and ownership tests.⁠Source 1⁠Source 2⁠Source 3

Stocks or bonds that you hold directly outside a financial account are not themselves foreign financial accounts merely because the issuer is foreign. They may require separate Form 8938 analysis.⁠Source 3⁠Source 4

Determine the greatest value of the entire account during the year

Start with the broker's statements or dated portfolio valuations. Each should show the value of investments plus cash and other assets in that account. Identify the largest reasonably evidenced account total during the reporting calendar year—not simply December 31 and not only the highest cash balance.⁠Source 1⁠Source 2⁠Source 3

You may rely on periodic statements when they fairly reflect the account's maximum. But if you know a big sale, transfer or market spike occurred between statements, review transaction data and other reliable valuations rather than blindly using a monthly snapshot.⁠Source 1⁠Source 3

An account can contain multiple currencies or securities quoted in different currencies. Work out the account total consistently in its reporting currency before performing the FBAR dollar conversion. Do not simply sum values in EUR, GBP and USD as if they were the same unit.⁠Source 1⁠Source 3

Convert the reported maximum to U.S. dollars

After identifying each account's annual maximum in its account currency, use the U.S. Treasury exchange rate for the final day of the reporting calendar year. If no Treasury rate is available, FinCEN permits another verifiable exchange rate with the source identified. Round U.S.-dollar amounts upward to the next whole dollar under the instructions.⁠Source 1

Do not convert each day's valuation at that day's spot rate and choose the largest converted amount as the default FBAR method. For other account currencies and complex multi-currency valuations, retain calculations and the source used. See maximum values and exchange rates.⁠Source 1⁠Source 3

Worked example: shares, ETFs and cash

Suppose a foreign brokerage account's quarterly statements show total account values of €22,000, €34,500, €29,700 and €31,800, where each total includes portfolio holdings and cash. If there was no known higher intervening value and the statements fairly reflect the maximum, use €34,500 as the reasonable annual account maximum before USD conversion.⁠Source 1⁠Source 3

Even if most of that value is in U.S. shares, it is still a foreign securities account when maintained outside the United States. Report the broker account rather than creating separate FBAR account records for each shareholding. The reported total is not merely the cash sweep sub-balance unless the sweep is a distinct reportable account.⁠Source 1⁠Source 2⁠Source 3

Situations requiring a closer look

Jointly owned investment accounts generally are not prorated to your ownership percentage for FBAR maximum-value reporting. Closed brokerage accounts can still count for the part of the year they existed. Closed-account rules and joint-account reporting explain the distinctions.⁠Source 1⁠Source 2⁠Source 3

Margin debt, a negative cash sub-balance, inaccessible securities, valuations unavailable from the custodian, or nested custodial accounts require careful review. Do not net all liabilities against an investment portfolio or substitute zero without checking FinCEN instructions and the specific account records.⁠Source 1⁠Source 3

Retain periodic statements, transaction histories for known peaks, evidence of the account's location and ownership, and the conversion working paper. See the FBAR recordkeeping guide.⁠Source 1⁠Source 2⁠Source 3

Do I report every individual stock on FBAR?

Generally no. Report a qualifying foreign securities/brokerage account and its account maximum; individual positions inside it are not ordinarily separate FBAR account lines.⁠Source 1⁠Source 2⁠Source 3

How do I calculate the FBAR value of a brokerage account?

Determine the highest reasonable total value of the account during the reporting year, including securities and cash, using portfolio statements or other reliable valuation evidence.⁠Source 1⁠Source 3

Do ETFs and mutual funds count in the brokerage account balance?

Their value generally contributes to the total value of a foreign securities account. A directly held interest in certain foreign pooled funds can require its own separate account analysis.⁠Source 1⁠Source 2⁠Source 3

Do I use the stock price on December 31?

Not by default. FBAR uses the account's annual maximum, not merely its final trading-day valuation.⁠Source 1⁠Source 3

What if my portfolio increased between statements?

Periodic statements are acceptable if they fairly reflect the greatest value. If you know they miss a higher account value, investigate available transactions or reliable records.⁠Source 1⁠Source 3

Should I report brokerage cash separately from my shares?

Typically include the cash shown within the same brokerage account's value; analyze separately only if you actually have another distinct reportable financial account.⁠Source 1⁠Source 2⁠Source 3

What if I own foreign-company shares directly without a broker?

Directly held shares are not themselves a foreign financial account for FBAR, but could be specified foreign financial assets for Form 8938.⁠Source 3⁠Source 4

How do I convert a euro brokerage account to dollars for FBAR?

Identify the highest reasonable EUR account value in the reporting year, then use the year-end U.S. Treasury rate as instructed by FinCEN; keep the rate source.⁠Source 1

Does a foreign broker holding U.S. stocks count?

The location of the account, not the country where the securities were issued, generally controls whether it is a foreign financial account.⁠Source 1⁠Source 2⁠Source 3

Does a closed foreign brokerage account still need to be reported?

Potentially. If a filing is required, a reportable account held during the year can remain reportable after closure; use its maximum while open.⁠Source 1⁠Source 3

Can I subtract margin loans from the portfolio value?

Do not automatically subtract brokerage debts or negative positions. Review how your broker reports total account value and the current FinCEN instructions; get help for complex cases.⁠Source 1⁠Source 3

Do I report securities for Form 8938 as well?

A foreign brokerage account and some investments may trigger Form 8938 depending on separate rules and thresholds; the FBAR filing does not replace Form 8938.⁠Source 4

Common questions

Next pages

Sources

Official sources used for this page.

  1. Source 1: FinCEN, Reporting Maximum Account Value (opens in a new tab)

    Annual maximum account value, nonmonetary assets, currency conversion, rounding and statement evidence.

    fincen.govChecked Back to text

  2. Source 2: IRS, How to report foreign bank and financial accounts (opens in a new tab)

    Brokerage accounts as foreign accounts and joint-ownership reporting.

    irs.govChecked Back to text

  3. Source 3: IRS, IRM 4.26.16 — Report of Foreign Bank and Financial Accounts (opens in a new tab)

    Definitions of reportable securities accounts, directly held assets and valuation.

    irs.govChecked Source updated Back to text

  4. Source 4: IRS, Comparison of Form 8938 and FBAR requirements (opens in a new tab)

    Distinction between FBAR securities accounts and Form 8938 investment assets.

    irs.govChecked Back to text

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