Skip to content
FBAR Guard

Must I report my child's foreign bank account if I'm listed as a parent or guardian?

Updated

Checked against official sources on How we check

Short answer

Only if the bank's arrangement gives you a reportable role; being the parent or guardian isn't enough. You report it on your own FBAR if you are a named joint owner or the bank will act on your instructions to withdraw or transfer the money. Your foreign accounts must also total more than $10,000. Separately, your child, if a U.S. person, may need their own FBAR; if they can't sign it, you sign it for them.⁠Source 1⁠Source 2⁠Source 3

How the rule works

Signature authority is the power to move money from an account by instructing the bank directly, alone or together with someone else. If the bank lets you withdraw from or transfer out of your child's account, you have it. If you are named as a joint owner, you have a financial interest instead. If you can only view the account, you have neither. Filing and signing your child's FBAR as parent or guardian doesn't give you signature authority over the account or put it on your own FBAR.⁠Source 1⁠Source 2⁠Source 3

Example

Your U.S.-citizen child has a foreign account worth $15,000 in the child's name, and the bank accepts your instructions to withdraw from it. You include the account on your own FBAR if your foreign accounts total more than $10,000. Your child also needs an FBAR; if the child can't sign it, you file it, sign it and enter “Parent/Guardian filing for child” in Item 45.⁠Source 3⁠Source 2

What to check

Check what the bank's mandate lets you do with your child's account: whether you are named as a joint owner, can withdraw or transfer money, or can only view it. Then work out your own aggregate and your child's aggregate separately.⁠Source 3⁠Source 2

Related questions

Full rules and more examples: Joint accounts, spouses and children

Sources

Official sources used for this page.

  1. Source 1: eCFR, 31 CFR § 1010.350 — Reports of foreign financial accounts (opens in a new tab)

    Who has a reportable financial interest in accounts, the rule for owners of record and the definition of signature authority.

    ecfr.govChecked Back to text

  2. Source 2: IRS, Internal Revenue Manual 4.26.16 — FBAR (opens in a new tab)

    Financial interests, signature authority, U.S. residency (including 6013(g)/(h) elections and treaties), family attribution, spousal filing, Form 114a parts and amended-FBAR identifiers.

    irs.govChecked Source updated Back to text

  3. Source 3: FinCEN, Filing for Child (opens in a new tab)

    Children's independent filing obligations and parent/guardian signature procedure.

    fincen.govChecked Back to text