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Do I report my Dutch bank accounts on the FBAR?

Updated

Checked against official sources on How we check

Short answer

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.⁠Source 1⁠Source 2

That includes online-only banks such as bunq and Knab. Each account with its own account number is listed separately, with its own highest balance during the year.⁠Source 1⁠Source 3

A savings account shown under the same login as your current account is still a separate account if it has its own account number.

Dutch bank accounts, in FBAR terms

What it is
A betaalrekening is the everyday current account your salary is paid into. A spaarrekening is a savings account at the same or another bank. Both hold deposits at a bank located outside the United States.⁠Source 1
On the FBAR
The FBAR treats each as a bank account. For every account you enter the bank's name and address, the account number and its maximum value in dollars.⁠Source 1⁠Source 4
On your statement
Use your statements or the bank's year overview (jaaroverzicht) to find each account's highest balance, not the December 31 balance. FinCEN accepts a reasonable approximation based on periodic statements.⁠Source 3

How Dutch banks show your accounts

Dutch banking apps often show a current account and one or more savings accounts on a single screen. What counts is the account number, not the screen.⁠Source 1⁠Source 4

If a savings account or a bunq sub-account has its own IBAN or account number, report it as its own account. Money that sits under the same account number belongs to one account.⁠Source 4

Salary that arrives and leaves within days still counts. The maximum value is the highest balance at any point, even for a single day.⁠Source 3

Example

Example

Olivia, a U.S. citizen in Rotterdam

Olivia has an ING betaalrekening that peaked at €4,800 when her salary and holiday allowance arrived in May. Her ING savings account, shown in the same app, peaked at €7,300 in December.⁠Source 3

She also keeps a bunq account for shared costs that peaked at €1,150. Converted at the December 31 Treasury rate, the three peaks total well over $10,000.⁠Source 3⁠Source 2

Olivia lists three accounts, each with its own number and its own highest value. The small bunq account is included because her total is over the threshold.⁠Source 5⁠Source 3

Common mistake

Reporting the ING current account and savings account as one entry because they share a login. Each account number is a separate account with its own maximum value.⁠Source 4⁠Source 3

More on this question

Are bunq and Knab accounts reportable?

Yes. An account with a bank located outside the United States is a foreign bank account, whether or not the bank has branches. They count toward the $10,000 total like any other Dutch account.⁠Source 1⁠Source 2

Do I report a Dutch account with a very small balance?

Yes, once your foreign accounts together exceed $10,000. Every reportable account is then listed, however small.⁠Source 5

Is a joint en/of account reported differently?

Yes. A joint account goes in the joint-account part of the form, at its full value, with the other owner's details.⁠Source 6

My bank already reports me under FATCA. Do I still list these accounts?

Yes. FATCA reporting is your bank's obligation to the tax authorities. The FBAR is your own report to FinCEN.⁠Source 7⁠Source 8

Related questions

Full rules and more examples: Reportable foreign accounts

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, 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 Back to text

  3. 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 Back to text

  4. Source 4: FinCEN, BSA Electronic Filing Requirements for FinCEN Form 114 (line item instructions) (opens in a new tab)

    Form fields, record retention, identification without a U.S. TIN and amendment fields.

    fincen.govChecked Back to text

  5. Source 5: 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

  6. Source 6: FinCEN, Reporting Jointly Held Accounts (opens in a new tab)

    Part III instructions, full account values, joint owner count, principal joint owner identity and blank items.

    fincen.govChecked Back to text

  7. Source 7: IRS, Foreign Account Tax Compliance Act (FATCA) (opens in a new tab)

    Reporting of U.S. account holders by foreign financial institutions.

    irs.govChecked Back to text

  8. Source 8: IRS, Comparison of Form 8938 and FBAR requirements (opens in a new tab)

    Side-by-side rules for Form 8938 and the FBAR.

    irs.govChecked Back to text