FBAR (FinCEN 114): Complete Guide for Non-Residents

Report of Foreign Bank and Financial Accounts — everything non-resident entrepreneurs need to know about filing FBAR (FinCEN 114), including who needs to file, deadlines, penalties, and step-by-step instructions.

What is FBAR (FinCEN 114)?

FBAR (FinCEN 114) (Report of Foreign Bank and Financial Accounts) FBAR (Report of Foreign Bank and Financial Accounts) is filed with FinCEN (Financial Crimes Enforcement Network), not the IRS. It reports foreign financial accounts including bank accounts, brokerage accounts, mutual funds, and other types of financial accounts maintained with a foreign financial institution.

DetailInformation
Official NameReport of Foreign Bank and Financial Accounts
Filing DeadlineApril 15 with an automatic extension to October 15. No form needs to be filed for the extension — it's automatic.
Penalty for Non-FilingNon-willful: up to $12,500 per violation. Willful: up to $100,000 or 50% of account balance (whichever is greater) per violation. Criminal penalties of up to $250,000 and/or 5 years imprisonment for willful failure.
Filed WithFinCEN (online via BSA E-Filing)

Who Needs to File FBAR (FinCEN 114)?

US persons (citizens, residents, and entities) with a financial interest in or signature authority over foreign financial accounts if the aggregate value of all foreign accounts exceeds $10,000 at any time during the calendar year.

Non-Resident Relevance

If you are a non-resident entrepreneur with a US LLC or US-source income, FBAR (FinCEN 114) may be a critical part of your US tax compliance. Consult with a qualified tax professional to determine if this form applies to your situation.

Filing Deadline

April 15 with an automatic extension to October 15. No form needs to be filed for the extension — it's automatic.

Filing on time is critical. The FBAR has an automatic extension to October 15 — no additional form is needed to get this extension.

Penalties for Non-Compliance

Penalty Warning

Non-willful: up to $12,500 per violation. Willful: up to $100,000 or 50% of account balance (whichever is greater) per violation. Criminal penalties of up to $250,000 and/or 5 years imprisonment for willful failure.

The IRS enforces these penalties strictly, especially for information returns related to foreign-owned entities. In many cases, there is no reasonable cause exception, making timely filing essential.

How to Complete FBAR (FinCEN 114)

Here is a section-by-section breakdown of FBAR (FinCEN 114):

Filer Information

Name, address, SSN/ITIN, and filing type (individual, consolidated, joint).

Account Information

For each foreign account: financial institution name, account number, type of account, currency, maximum account value during the year, and country.

Joint Account Holders

Information about other account holders for jointly-owned accounts.

Filing Tip

Given the complexity and steep penalties associated with FBAR (FinCEN 114), we strongly recommend working with a qualified tax professional who has experience with non-resident tax filings. Errors or omissions can trigger significant penalties.

Common Mistakes to Avoid

These are the most frequent errors we see when clients attempt to file FBAR (FinCEN 114) on their own:

  1. Not filing because individual accounts are under $10,000 (the threshold applies to the aggregate of ALL foreign accounts)
  2. Confusing FBAR with Form 8938 (different forms, different agencies, different thresholds)
  3. Not reporting accounts you have signature authority over (even if you don't own the account)
  4. Using the wrong maximum value (should be the highest balance at any point during the year)
  5. Not converting to USD using the Treasury Department's year-end exchange rate
  6. Not filing for a US LLC's foreign account (the LLC is a US person)

Need Help Filing FBAR (FinCEN 114)?

Our tax experts specialize in preparing and filing FBAR (FinCEN 114) for non-resident entrepreneurs. Avoid costly penalties — let us handle it.

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