If I owe no Box 3 tax, do I still file an FBAR?

Yes, if your foreign accounts together exceeded $10,000. The FBAR does not depend on owing tax in either country.

Can I use my Box 3 actual-return figures on the FBAR?

No. An actual-return claim measures what your assets earned. The FBAR asks for each account's highest balance, whatever it earned.

Does the Dutch tax authority send my FBAR to the IRS?

No. You file the FBAR yourself with FinCEN. Separately, Dutch banks report U.S. account holders under FATCA.

Box 3 and the FBAR: what is the difference?

Updated 9 Nov 2026

Checked against official sources on 4 Nov 2026How we check

Short answer

They are two separate obligations: Box 3 is a Dutch tax on your net savings and investments, and the FBAR is a U.S. report of your foreign accounts.⁠^{[1]Source 1}⁠^{[2]Source 2}

Filing one never replaces the other, and the numbers are measured differently. Box 3 starts from your assets and debts on 1 January; the FBAR uses each account's highest balance in the year.⁠^{[1]Source 1}⁠^{[3]Source 3}

Side by side

	Box 3 (Dutch tax return)	FBAR (FinCEN Form 114)
What it is	Income tax on savings and investments, minus debts	A report of foreign accounts; no tax is due
Filed with	Belastingdienst	FinCEN, through BSA E-Filing
Value used	Assets and debts on 1 January (peildatum)	Each account's highest value during the year
What is taxed	A deemed return per asset class, or your actual return if that is lower and you report it	Nothing; the FBAR is a report only
Currency	Euros	U.S. dollars at the Treasury December 31 rate
Due	1 May, unless extended	April 15, with an automatic extension to October 15
Threshold	Tax-free allowance (€59,357 per person in 2026)	More than $10,000 across all foreign accounts

Sources⁠^{[1]Source 1}⁠^{[4]Source 4}⁠^{[2]Source 2}⁠^{[3]Source 3}⁠^{[5]Source 5}

The Belastingdienst expects a new box 3 system, taxing actual returns, probably from 1 January 2028. The FBAR rules do not change with it.⁠^{[4]Source 4}⁠^{[2]Source 2}

Example

Daniel in Haarlem

Daniel's savings were €22,000 on 1 January, which is the balance his Box 3 return uses. In June an inheritance pushed the same account to €61,000.⁠^{[1]Source 1}⁠^{[3]Source 3}

His FBAR reports the June peak, converted at the December 31 Treasury rate, not the January figure from his Dutch return.⁠^{[3]Source 3}

Common mistake

Copying the 1 January balance from the Dutch return onto the FBAR. The FBAR needs the year's highest balance, which is often higher.⁠^{[3]Source 3}

Sources

Official sources used for this page.

Source 1: Belastingdienst, Hoe is het box 3-inkomen op mijn voorlopige aanslag 2026 berekend? (opens in a new tab)
Box 3 values assets and debts on 1 January; deemed-return percentages and the €59,357 tax-free allowance for 2026.
belastingdienst.nlChecked 4 Nov 2026Back to text
Source 2: IRS, Report of Foreign Bank and Financial Accounts (FBAR) (opens in a new tab)
U.S.-person and $10,000 tests, spousal exception, irrelevance of income-tax filing status and extensions for certain employees and officers.
irs.govChecked 4 Nov 2026Back to text
Source 3: FinCEN, Reporting Maximum Account Value (opens in a new tab)
Maximum account value for cash and nonmonetary assets, account-by-account values and currency conversion, including another verifiable rate with its source.
fincen.govChecked 4 Nov 2026Back to text
Source 4: Belastingdienst, Wat is mijn werkelijk rendement? (opens in a new tab)
The actual return is taxed when lower than the deemed return (Wet tegenbewijsregeling box 3); new box 3 rules expected probably from 1 January 2028.
belastingdienst.nlChecked 4 Nov 2026Back to text
Source 5: FinCEN, Due date for FBARs (opens in a new tab)
April 15 due date and automatic extension to October 15.
fincen.govChecked 4 Nov 2026Back to text
Source 6: IRS, Foreign Account Tax Compliance Act (FATCA) (opens in a new tab)
Reporting of U.S. account holders by foreign financial institutions.
irs.govChecked 4 Nov 2026Back to text