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Do I add up accounts in different European countries for the FBAR?

Updated

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Short answer

Yes, the $10,000 test covers all your foreign accounts together, wherever they are and whatever their currency.⁠Source 1

Convert each account's highest value at the Treasury rate for December 31 of the year, then add them up. If the total exceeds $10,000, report every account.⁠Source 2⁠Source 3

A U.S.-dollar account at a European bank is a foreign account and counts toward the total.

Worked example

Hannah lives in Brussels. Her accounts in three currencies never exceeded $10,000 on their own. The rates below are illustrative, not Treasury's published figures; Treasury quotes foreign currency per dollar, so divide.⁠Source 2⁠Source 4

Belgian current account€3,800 ÷ 0.870 (illustrative)
$4,368
UK savings account£2,600 ÷ 0.760 (illustrative)
$3,422
Swiss account from a former jobCHF 2,100 ÷ 0.810 (illustrative)
$2,593
U.S.-dollar account at a Belgian bankno conversion
$1,500
Combined total
$11,883

The total exceeds $10,000, so Hannah reports all four accounts, each at its own maximum. Each converted figure is rounded up to the next whole dollar.⁠Source 2⁠Source 3

The rules behind the total

Peaks on different days are still added together. The test uses each account's maximum, not the combined balance on any single day.⁠Source 3⁠Source 2

Use the Treasury rate for December 31 for every currency. If Treasury publishes no rate for a currency, use another verifiable rate and name its source.⁠Source 2

Accounts at banks inside the United States are not part of the total.⁠Source 5

Below the line

Example

Carlos in Madrid

Carlos has a Spanish account that peaked at €6,000 and an old Mexican account that peaked at MXN 40,000. At illustrative rates of 0.870 and 18.50 per dollar, that is $6,897 plus $2,163.⁠Source 2

His total is $9,060, under $10,000, so he has no FBAR for that year. He keeps the figures and the rates he used.⁠Source 1⁠Source 6

Common mistake

Testing each country, or each account, against $10,000 separately. The threshold applies to the combined maximums of all foreign accounts.⁠Source 1⁠Source 3

More on this question

Does a U.S.-dollar account at a European bank count as foreign?

Yes. Location decides, not currency. A dollar account at a bank in Amsterdam or Frankfurt is a foreign account and needs no conversion.⁠Source 5⁠Source 2

Do Revolut or N26 accounts count toward the total?

Yes, when your account terms name a bank outside the United States. If the terms say the balance is held as e-money instead, its status is unsettled; the fintech page covers it.⁠Source 3⁠Source 5

Once I'm over $10,000, do small accounts still go on the form?

Yes. Every reportable account is listed, however small its balance.⁠Source 3

Related questions

Full rules and more examples: The $10,000 aggregate threshold

Sources

Official sources used for this page.

  1. Source 1: 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

  2. Source 2: 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

  3. Source 3: 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

  4. Source 4: U.S. Treasury, Treasury Reporting Rates of Exchange (opens in a new tab)

    Year-end exchange rates used for the FBAR.

    fiscaldata.treasury.govChecked Back to text

  5. Source 5: 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

  6. Source 6: FinCEN, Record Keeping (opens in a new tab)

    Records each filer must keep and the employee exception.

    fincen.govChecked Back to text