FBAR questions: Americans in the Netherlands
Dutch current, savings and investment accounts, en/of accounts, lijfrente, pensions and Box 3, and how each fits the FBAR.
8 questions
- Box 3 and the FBAR: what is the difference?They are two separate obligations: Box 3 is a Dutch tax on your net savings and investments, and the FBAR is a U.
- Do Americans living in the Netherlands need to file an FBAR?Yes, if your accounts outside the United States together exceeded $10,000 at any time during the year.
- Do I report my Bitvavo account on the FBAR?Not if it holds only crypto: under FinCEN Notice 2020-2, a foreign account holding only virtual currency is not reportable on the FBAR.
- Do I report my Dutch bank accounts on the FBAR?Yes, every Dutch current account (betaalrekening) and savings account (spaarrekening) is a foreign bank account and goes on your FBAR when your foreign accounts together exceed $10,000.
- Do I report my Dutch pension on the FBAR?The answer is unsettled for collective pension funds such as ABP or PFZW: neither FinCEN nor the IRS has issued guidance on them.
- How do I file an FBAR from the Netherlands?File online through FinCEN's BSA E-Filing System; it is free and individuals don't need to register.
- How do I report a joint en/of account with my Dutch spouse on the FBAR?Report the full highest balance of the en/of account on your own FBAR, and enter your Dutch spouse as the principal joint owner.
- Is a Dutch lijfrenterekening reportable on the FBAR?Yes, a lijfrenterekening is a blocked savings account at a bank, so it is a foreign bank account for the FBAR.