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Is a Dutch lijfrenterekening reportable on the FBAR?

Updated

Checked against official sources on How we check

Short answer

Yes, a lijfrenterekening is a blocked savings account at a bank, so it is a foreign bank account for the FBAR.⁠Source 1⁠Source 2

The investment version, a lijfrentebeleggingsrecht, holds fund units or securities for you and fits the securities or pooled-fund account definitions. Report each at its highest value in the year.⁠Source 1⁠Source 3

The FBAR retirement-plan exception covers U.S. plans only; Dutch tax-favored retirement saving gets no exception.

What lijfrente products are, in FBAR terms

What it is
A lijfrenterekening (banksparen) is a blocked account for tax-favored Dutch retirement saving. The Belastingdienst requires the account to be blocked; providers such as Brand New Day Bank describe theirs as a geblokkeerde rekening.⁠Source 2⁠Source 4
On the FBAR
Being blocked until retirement does not change the account type. It is a bank account in your name at a Dutch bank, and the U.S. retirement-plan exception does not extend to it. No FinCEN guidance names lijfrente products; this follows from the account definitions.⁠Source 1⁠Source 3
On your statement
Use the yearly statement or the provider's online overview for the highest value. For an investment version, use the total value of the units, plus any cash.⁠Source 5

A workplace pension is a different product

A pension your employer arranges, with a pension fund, an insurer or a premium pension institution such as Brand New Day, is not a lijfrente. The provider holds the assets and you hold a pension entitlement.⁠Source 2

FinCEN and the IRS have not addressed Dutch workplace pensions, so their FBAR treatment is unsettled. The Dutch pension page covers what is known and what is open.⁠Source 3⁠Source 6

Example

Example

Nathan, a freelancer in Amersfoort

Nathan has no workplace pension, so he saves through a lijfrenterekening that reached €14,200 in December. He also has a lijfrentebeleggingsrecht that peaked at €9,600 in July.⁠Source 5

Both go on his FBAR as separate accounts, each at its own peak converted at the December 31 Treasury rate. They also count toward his $10,000 total.⁠Source 5⁠Source 7

Common mistake

Leaving the lijfrenterekening off because the money can't be withdrawn before retirement. Withdrawal limits do not create an FBAR exception.⁠Source 1⁠Source 3

More on this question

Is a lijfrente in its payout phase still reportable?

Yes, while the account still holds a balance. A paying-out lijfrenterekening is still a blocked bank account until it is fully paid out.⁠Source 1⁠Source 4

What about a lijfrenteverzekering with an insurer?

The IRS lists insurance and annuity policies with a cash value as accounts. No guidance addresses blocked Dutch lijfrente policies; ask the insurer for the policy value each year and keep it.⁠Source 3

Does a lijfrente count toward the $10,000?

Yes. Its highest value is added to your other foreign accounts when you test the threshold.⁠Source 7⁠Source 3

Related questions

Full rules and more examples: Foreign pensions and the FBAR

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: Belastingdienst, Vragen en antwoorden over lijfrenten (IB 802) (opens in a new tab)

    A lijfrentespaarrekening must be a blocked account; the lijfrentebeleggingsrecht is its investment version.

    download.belastingdienst.nlChecked 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: Brand New Day Bank (product terms), Algemene voorwaarden Uitkerende Lijfrenterekening (opens in a new tab)

    Describes a lijfrenterekening as a blocked bank account for retirement saving; product description only.

    brandnewday.nlChecked Back to text

  5. Source 5: 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

  6. Source 6: Federal Register, 76 FR 10234 — Final rule on reports of foreign financial accounts (2011) (opens in a new tab)

    FinCEN's explanation of financial interest, trusts and signature authority.

    federalregister.govChecked Source updated Back to text

  7. Source 7: 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