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FBAR Filing Checklist

Estimated time: 45-60 minutes

Description

The FBAR Filing Checklist is an essential tool designed for U.S. persons who hold financial accounts in foreign countries and must report them to the Financial Crimes Enforcement Network (FinCEN). Under the Bank Secrecy Act, any U.S. citizen, resident, or entity with a financial interest in or signature authority over foreign financial accounts exceeding $10,000 in aggregate value at any point during the calendar year must file FinCEN Form 114, commonly known as the FBAR. This checklist walks you through every step of the filing process, from identifying which accounts must be reported to gathering the necessary documentation, calculating aggregate balances, and submitting the form electronically through the BSA E-Filing System. It covers joint accounts, accounts held by spouses, trust accounts, and accounts over which you have signature authority but no financial interest. The checklist also addresses common pitfalls such as failing to convert foreign currency balances to U.S. dollars using the correct Treasury exchange rate, missing accounts at foreign branches of U.S. banks, and overlooking retirement or pension accounts that may qualify as reportable foreign financial accounts. Whether you are filing for the first time or are an experienced filer looking to ensure compliance, this checklist provides a systematic approach to meeting your FBAR obligations and avoiding potentially severe civil and criminal penalties for non-compliance.

Steps

1

Identify All Foreign Financial Accounts

List every foreign bank account, securities account, mutual fund, and other financial account held outside the United States during the reporting year.

2

Determine Aggregate Value Threshold

Calculate the maximum value of each foreign account during the calendar year and sum them to determine if the $10,000 aggregate threshold is met.

3

Gather Account Documentation

Collect bank statements, account opening documents, and year-end balance statements for each reportable foreign account.

4

Convert Foreign Currency to USD

Use the official Treasury Department exchange rates to convert all foreign currency balances to U.S. dollars for accurate reporting.

5

Complete FinCEN Form 114

Fill out all required fields on the FBAR form including account types, maximum values, financial institution details, and account numbers.

6

Review for Accuracy and Completeness

Double-check all entries against source documents, verify account numbers, and ensure no reportable accounts have been omitted.

7

File Electronically via BSA E-Filing

Submit the completed FBAR through the BSA E-Filing System before the April 15 deadline, noting the automatic extension to October 15.

Applicable Forms

FinCEN 114Form 8938

Target Audience

U.S. citizens and residents with foreign financial accounts exceeding $10,000 in aggregate value during the tax year

Frequently Asked Questions

Who is required to file an FBAR?
Any U.S. person — including citizens, green card holders, and resident aliens — who has a financial interest in or signature authority over one or more foreign financial accounts must file an FBAR if the aggregate value of all foreign accounts exceeds $10,000 at any time during the calendar year. This includes bank accounts, brokerage accounts, mutual funds, and certain foreign retirement accounts.
What happens if I miss the FBAR filing deadline?
The FBAR is due on April 15 with an automatic extension to October 15 — no extension request is needed. If you fail to file, penalties can be severe: non-willful violations can result in penalties up to $10,000 per violation, while willful violations can lead to penalties of up to $100,000 or 50% of the account balance, whichever is greater, along with potential criminal prosecution.
Does the FBAR replace FATCA Form 8938 reporting?
No, the FBAR (FinCEN Form 114) and FATCA (Form 8938) are separate reporting requirements with different thresholds, different filing locations, and different penalties. Many taxpayers with foreign accounts must file both. The FBAR is filed with FinCEN while Form 8938 is filed with your tax return. Our checklist helps you determine your obligations under both regimes.

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