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Do Americans living in the Netherlands need to file an FBAR?

Updated

Checked against official sources on How we check

Short answer

Yes, if your accounts outside the United States together exceeded $10,000 at any time during the year.⁠Source 1

U.S. citizens and green card holders are U.S. persons for FBAR purposes wherever they live. Your ING, Rabobank or bunq account is a foreign account even though the Netherlands is home.⁠Source 2⁠Source 3

Living in the Netherlands, paying Dutch tax or being reported by your bank under FATCA does not replace the FBAR.

Who files and who doesn't

You file

  • U.S. citizens, including people born in the U.S. who have never lived there.⁠Source 2
  • Green card holders, for every year they hold the card, even while living in the Netherlands.⁠Source 4
  • Anyone whose Dutch and other foreign accounts together exceeded $10,000 at any point in the year.⁠Source 1

No FBAR needed

  • A Dutch spouse or partner who is not a U.S. citizen or resident. Only U.S. persons file.⁠Source 3
  • A year in which your foreign accounts together never went above $10,000.⁠Source 1
  • Accounts held at a bank inside the United States.⁠Source 3

How it plays out in the Netherlands

Count every account: current account (betaalrekening), savings (spaarrekening), investment account (beleggingsrekening) and blocked retirement savings such as a lijfrenterekening. Each IBAN is a separate account on the form.⁠Source 3⁠Source 5

The FBAR is due April 15 after the calendar year, with an automatic extension to October 15. It does not follow the Dutch 1 May tax return deadline.⁠Source 1⁠Source 6

You file online with FinCEN through the BSA E-Filing System. Filing yourself is free.⁠Source 7

Example

Example

Sophie, a U.S. citizen in Utrecht

Sophie's ING current account peaked at €6,200 in March, when her salary and holiday allowance arrived together. Her ING savings account peaked at €5,900 in December.⁠Source 8

Converted at the year-end Treasury rate, the two peaks add up to well over $10,000. Sophie files an FBAR listing both accounts, each with its own highest value.⁠Source 8⁠Source 1

Common mistake

Thinking the Dutch accounts are "local" and therefore not foreign. For the FBAR, any account at a bank outside the United States is foreign, wherever you live.⁠Source 3

More on this question

Does declaring my savings in Box 3 replace the FBAR?

No. Box 3 is the Dutch tax on savings and investments, declared to the Belastingdienst. The FBAR is a separate U.S. report to FinCEN, so you may need both for the same accounts.⁠Source 9⁠Source 1

My Dutch bank already reports me under FATCA. Do I still file?

Yes. FATCA reporting is your bank's obligation. The FBAR is your own report to FinCEN, and your bank's report does not replace it.⁠Source 10⁠Source 11

I was born in the U.S. but have never lived there. Do I file?

Yes, if you are a U.S. citizen and your foreign accounts together exceeded $10,000. Having no Social Security number does not remove the requirement; the form accepts a passport or foreign tax number.⁠Source 2⁠Source 5

Related questions

Full rules and more examples: What is an FBAR?

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, 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

  3. Source 3: 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

  4. Source 4: 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

  5. Source 5: 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

  6. Source 6: FinCEN, Due date for FBARs (opens in a new tab)

    April 15 due date and automatic extension to October 15.

    fincen.govChecked Back to text

  7. Source 7: FinCEN, BSA E-Filing: File an FBAR as an individual (opens in a new tab)

    Free filing without registration; online and PDF forms.

    bsaefiling.fincen.treas.govChecked Back to text

  8. Source 8: 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

  9. Source 9: 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 Back to text

  10. Source 10: 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

  11. Source 11: 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