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FBAR Guard

How do I report a joint en/of account with my Dutch spouse on the FBAR?

Updated

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Short answer

Report the full highest balance of the en/of account on your own FBAR, and enter your Dutch spouse as the principal joint owner.⁠Source 1

Each joint owner reports the entire value, not a half share. If your spouse is not a U.S. person, your spouse has no FBAR to file.⁠Source 1⁠Source 2

Never divide a joint account's balance by two on the FBAR.

How the joint-account rules apply

What you enter

  • You report the account in Part III, the joint-account part, at its full maximum value.⁠Source 1⁠Source 3
  • The number of joint owners excludes you. With only your spouse on the account, enter 1.⁠Source 1
  • Your spouse is the principal joint owner. Enter their name and address, and a tax number if they have one; a foreign number such as a Dutch BSN is accepted.⁠Source 1
  • A spouse living abroad without a U.S. mailing address gives their foreign address.⁠Source 1

What does not apply

  • A spouse who is not a U.S. citizen, green card holder or U.S. resident files no FBAR.⁠Source 2⁠Source 4
  • Form 114a is not needed with a non-U.S. spouse. It is for two spouses who both have to file and choose to file one report.⁠Source 5
  • Accounts in your spouse's name alone are not on your FBAR unless you can move money from them.⁠Source 2

If you are both Americans

Spouses who are both U.S. persons can file one FBAR only if every reportable account of the non-filing spouse is held jointly with the filing spouse. Both then sign Form 114a and keep it; it is not sent to FinCEN.⁠Source 5⁠Source 6

If either spouse has a separate account, such as a savings account in one name, each spouse files their own FBAR. Each then reports the full value of the joint accounts.⁠Source 5

Example

Example

Jake and Marieke in Leiden

Jake is a U.S. citizen; his wife Marieke is Dutch only. Their Rabobank en/of account peaked at €38,500 in August, after they sold a car and before they paid a renovation invoice.⁠Source 7

Jake reports the account in Part III at the full €38,500, converted at the December 31 Treasury rate. He lists Marieke as principal joint owner with her BSN and their Leiden address. Marieke files nothing.⁠Source 1⁠Source 7

Common mistake

Reporting half the balance because the money is shared. FinCEN requires each joint owner to report the account's entire value.⁠Source 1

More on this question

Does my Dutch spouse have to give a U.S. tax number?

No. Your spouse needs no U.S. number for your FBAR. The principal joint owner's tax number can be a foreign number.⁠Source 1

We are both Americans with only joint Dutch accounts. One FBAR or two?

You can file one if all of the non-filing spouse's reportable accounts are joint with the filing spouse. Both sign Form 114a and keep it with your records.⁠Source 5⁠Source 6

My Dutch spouse has a separate savings account. Do I report it?

No, if you cannot move money from it. It is your spouse's account, and a non-U.S. spouse has no FBAR.⁠Source 2

Related questions

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

Sources

Official sources used for this page.

  1. Source 1: 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

  2. Source 2: 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

  3. Source 3: 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

  4. Source 4: FinCEN, Who is a United States person? (opens in a new tab)

    Citizens, residents and U.S. entities, including disregarded entities.

    fincen.govChecked Back to text

  5. Source 5: FinCEN, Filing for Spouse (opens in a new tab)

    Three conditions for reporting jointly owned accounts on one spouse's FBAR and use of Form 114a.

    fincen.govChecked Back to text

  6. Source 6: FinCEN, Form 114a — Record of Authorization to Electronically File FBARs (opens in a new tab)

    Authorization and recordkeeping for spousal or third-party electronic filings.

    fincen.govChecked Source updated Back to text

  7. Source 7: 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