FBAR Reporting Requirements (Updated for 2026)

Del Sol CPA
Jan 15
2 min read

Updated: Jan 15

Who Must File FBAR Reporting Requirements

U.S. persons (citizens, permanent residents, tax residents, corporations, trusts, estates) must file an FBAR if:

Have a financial interest in or signature authority over at least one foreign financial account.
The aggregate value of all foreign accounts exceeds USD 10,000 at any point during the calendar year.
Filing is required regardless of whether a U.S. tax return must also be filed.

Several account types should be taken into consideration when calculating if you met the USD 10,000 threshold for the year. You must include:

Foreign accounts that are not in your name but for which you have signature authority (i.e. you have control over them)
Foreign retirement accounts, pensions, etc.
Non-US-based cryptocurrency wallets
Foreign investment accounts holding assets such as stocks, mutual funds, insurance contracts

Example 1:

U.S. citizen in Taiwan with a local bank account peaking at USD 5,000 → No FBAR required.

FBAR Reporting Requirements

Example 2:

U.S. citizen in Taiwan with a bank account (USD 4,000) + MaiCoin crypto wallet (USD 7,500) → FBAR required (combined > USD 10,000).

Example 3:

U.S. citizen in New York with NTD 1,000,000 (~USD 31,000) at Land Bank of Taiwan’s New York branch → No FBAR required (account is U.S. based).

Conversely: Holding > USD 10,000 at Bank of America’s Hong Kong branch → FBAR required.

Exceptions

There are a few rare exceptions to the FBAR filing requirements. According to the IRS FBAR reference page, an account does not need to be reported if it is:

A Correspondent/Nostro account,
Owned by a governmental entity,
Owned by an international financial institution,
Maintained on a U.S. military banking facility,
Held in an individual retirement account (IRA) of which you’re an owner or beneficiary,
Held in a retirement plan of which you’re a participant or beneficiary, or
Part of a trust of which you’re a beneficiary is if a U.S. person (trust, trustee of the trust, or agent of the trust) files an FBAR reporting these accounts.

Filing Requirements in 2026

Threshold remains USD 10,000: U.S. persons must file an FBAR if the aggregate value of all foreign accounts exceeded USD 10,000 at any time during the calendar year.
Deadline for 2025 FBAR filing: Reports are due April 15, 2026, with an automatic extension to October 15, 2026 (no separate request required).
Electronic filing only: FBARs must be filed through the FinCEN BSA E-Filing System; they are separate from federal tax returns. If you want to paper-file your FBAR, you must call FinCEN's Resource Center to request an exemption from e-filing.
Penalties remain severe: Non-compliance can result in civil and criminal penalties, making timely filing essential.

Practical Guidance

In general, almost all U.S. persons who meet the threshold must file FBAR reports for their foreign accounts. If you are unsure about your obligations, it is strongly recommended to consult a tax professional to avoid costly mistakes.

How to Get Help with Your FBAR

In addition to standard tax filing and preparation services, the experts at Del Sol CPA and Associates continue to offer assistance with compliant FBAR filing each year.

Bilingual support available
Guidance on electronic filing
Help with record-keeping and compliance

If you have any questions or need personalized guidance, don’t hesitate to reach out to our team.