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Does my non-U.S. spouse need to sign Form 114a?

Updated

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Short answer

No. The spousal exception lets one spouse's FBAR cover a spouse who would otherwise have to file. Your non-U.S.-person spouse has no FBAR to file. There's no second FBAR to combine, so Form 114a isn't needed.⁠Source 1⁠Source 2

How the rule works

Form 114a is used for the spousal exception or to authorize a third party, such as a preparer, to file for you. Co-owning an account with someone who has no filing obligation doesn't call for either.⁠Source 3⁠Source 1

Example

A U.S. citizen and a non-U.S.-person spouse jointly own one reportable foreign account. The U.S. citizen files their own FBAR, reports the full value and names the spouse as principal joint owner in Part III.⁠Source 4⁠Source 1

What to check

Confirm both spouses' status for the year. If your spouse is in fact a U.S. resident, the spousal exception and Form 114a may apply. Keep any Form 114a you do sign; don't attach it to the FBAR.⁠Source 1⁠Source 3

Related questions

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

Sources

Official sources used for this page.

  1. Source 1: 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

  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, 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

  4. Source 4: 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