FBAR in Plain Terms: Who Must File, by When, and What If You Missed It

The FBAR is an annual report of bank and financial accounts held outside the US. Its official name is FinCEN Form 114, and it goes to the Treasury's Financial Crimes Enforcement Network ⁦(FinCEN)⁩, not the IRS. It isn't a tax return, no tax is calculated on it, and filing it costs nothing. It only reports what you have and where.

Who has to file

Every US citizen or green card holder, even one who has lived in Israel their whole life, whose accounts outside the US together passed $10,000 at any point during the year. Not at year end, at any moment. A salary and a bonus landing in the same week is enough.

• The amount is counted across all accounts together: checking, deposits, savings, investment portfolios, and under most professional approaches also a keren hishtalmut and provident funds
• For each account you take its highest balance of the year, and add them up
• A joint account with an Israeli spouse counts in full
• Signature authority without ownership also requires reporting, for example an elderly parent's account or the account of a business or nonprofit you can sign on

By when

The regular deadline is April 15, with an automatic extension to October 15, no request needed. In other words, the FBAR for 2025 can still be filed on time until October 15, 2026. After that date, it counts as late.

How to file

Online only, through FinCEN's BSA E-Filing System. It isn't attached to your tax return and isn't mailed. For each account you enter the bank's name and address, the account number, and the year's maximum balance in dollars, using the US Treasury's year-end exchange rate. Records must be kept for five years.

The FBAR isn't Form 8938, and you may need both

Form 8938 ⁦(FATCA)⁩ is a separate report attached to the tax return itself, with much higher thresholds for people living outside the US. Some people only need the FBAR, some need both. Filing one doesn't excuse the other.

Missed years? It isn't the end of the world

Most Israeli-Americans who never filed an FBAR simply didn't know it existed. The IRS has orderly routes for this:

• Someone who filed all their tax returns and reported all their income, and is only missing FBARs, can file them late with an explanation under the delinquent FBAR submission procedures. As long as the IRS hasn't contacted them first, a penalty is generally not imposed
• Someone who also didn't file tax returns, or didn't report income, generally turns to the Streamlined procedures, which bring three tax years and six FBAR years into compliance together

The penalty for non-willful failure to file is capped by law at roughly $10,000, adjusted each year for inflation. In 2023 the US Supreme Court held in Bittner that this penalty applies once per year, not once per account. Someone with ten accounts isn't exposed to ten penalties. Willful failure is a different story entirely, which is why it matters most to get compliant before the IRS reaches out, not after.

How we help

We go through your list of accounts with you, including the ones you didn't think of, check whether you crossed the threshold and in which years, and file the FBAR. If years are missing, we look at which route fits you, and coordinate with a licensed US accountant when tax returns are needed too. An initial check with no commitment.