FBAR and Form 8938: Reporting Your Bank Accounts Outside the US
A practical guide for Arab immigrants: who must file an FBAR, how to calculate the threshold, and how to fix missed years.
In short: If you are a US citizen, green card holder, or tax resident, and your accounts outside the US (in Egypt, Jordan, Iraq, or anywhere else) added up to more than $10,000 at any point in the year, you must file an FBAR (FinCEN Form 114) online. It is due April 15, with an automatic extension to October 15. You may also need IRS Form 8938 with your tax return if your foreign assets pass higher thresholds. The FBAR is not a tax, but skipping it can lead to serious penalties.
What is the FBAR, and why does it hit so many immigrant families?
The FBAR, or Report of Foreign Bank and Financial Accounts, is filed with the Treasury's Financial Crimes Enforcement Network (FinCEN), not attached to your tax return. It discloses that the accounts exist. It does not, by itself, create any tax.
Many Arab immigrants keep an account back home: an old salary account, a savings certificate at an Egyptian bank, a joint account with a parent, or an account that collects rent on the family apartment. Any of these can count. Plenty of people only learn about the rule years after arriving.
The good news: filing is free, online, and something most people can do themselves once they know what counts.
Who counts as a "US person"?
FinCEN's instructions define a United States person as US citizens (including minor children), US residents, and US entities such as corporations, LLCs, partnerships, and trusts.
- Green card holders are residents for tax purposes, so the rule applies to them.
- Visa holders (for example, work visas) can become tax residents under the substantial presence test: at least 31 days in the current year, and 183 days over three years counting all current-year days, one-third of last year's days, and one-sixth of the days from the year before that.
- F and J students can exclude their days under IRS rules if they meet the conditions, so many are not residents in their first years. Confirm your status rather than assuming.
- Children who are US citizens with an account in their own name abroad are covered too. A parent or guardian can file for them.
Unsure where you stand? Start with our US taxes guide for newcomers.
What is the threshold, and how do you calculate it?
As of September 2026, the rule is: if the combined value of all your foreign accounts exceeded $10,000 at any time during the calendar year, you file. It is the total that matters, not each account on its own, and it is the highest balance during the year, not the December 31 balance.
Example: A checking account in Jordan peaked at the equivalent of $6,000, and a savings certificate in Egypt peaked at $5,000. The total is $11,000, so you must file, and you report both accounts, not just the larger one.
- Find each account's maximum value in its own currency. Periodic statements are acceptable if they reasonably reflect the peak.
- Convert to dollars using the Treasury's Reporting Rates of Exchange for the last day of the year, not a street rate or the rate on the day you deposited.
- Round up to the next whole dollar, as the instructions require.
- Add the values and compare the total to $10,000.
Which accounts count, including power of attorney over a parent's account?
The definition is broad: checking, savings, time deposits, brokerage and securities accounts, foreign mutual funds, and insurance policies with cash value. A branch of a US bank located abroad is a foreign account. A branch of a foreign bank located inside the US is not.
It is not only about what you own. If you have signature authority, meaning you can move money by instructing the bank directly, you may have to report the account even if the money is your father's. That is a very common setup in Arab families, where one child holds a bank power of attorney for a parent.
Real estate and gold kept at home are not "financial accounts" for FBAR purposes. The income from them, such as rent, may still be taxable in the US depending on your status.
FBAR vs Form 8938 (FATCA): what's the difference?
These are two separate obligations, and the IRS says plainly that filing one does not replace the other. Form 8938 goes with your income tax return and has much higher thresholds.
| Item | FBAR (FinCEN 114) | Form 8938 |
|---|---|---|
| Filed with | FinCEN, via BSA E-Filing | IRS, attached to your income tax return |
| Single, living in the US | Over $10,000 at any time | Over $50,000 on the last day of the year or $75,000 at any time |
| Married filing jointly, living in the US | Same $10,000 test per person | Over $100,000 on the last day of the year or $150,000 at any time |
| Due date | April 15, automatic extension to October 15 | Your tax return due date, including extensions |
| If you don't need to file a tax return | You may still owe an FBAR | No Form 8938 required |
These figures come from the IRS comparison page as of September 2026. Higher thresholds apply if you live abroad. Check the official comparison on irs.gov before filing.
How do you file the FBAR, step by step?
- Gather details for every account: bank name and address, account number, account type, and maximum value for the year.
- Go to BSA E-Filing and choose to file an FBAR as an individual. Individuals don't need to register first.
- Use your name exactly as on your US tax documents. If your Egyptian passport says "Mohamed" and your SSN card says "Muhammad," match whatever your tax return uses.
- List each account in the right section: owned separately, owned jointly, or signature authority only.
- Sign electronically and save the confirmation.
- Keep records for five years from the due date, including statements.
Married couples: one spouse may file a single report covering joint accounts if certain conditions are met, including that all of the other spouse's reportable accounts are joint and both sign Form 114a, which you keep rather than send.
Your income tax return also asks, on Schedule B, whether you have foreign accounts. Answer accurately; a "no" there alongside an FBAR filing is an obvious mismatch. See our guide to your first tax return with a W-2 or 1099.
What are the penalties? The honest overview
The IRS says a non-willful failure to file can bring a penalty of up to $10,000. A willful violation can mean up to the greater of $100,000 or 50% of the account balance, plus possible criminal penalties. Those base amounts are adjusted for inflation each year.
For Form 8938, failing to file can cost up to $10,000, plus another $10,000 for every 30 days it stays unfiled after an IRS notice.
These are maximums, not automatic bills for everyone who filed late. What matters most is whether you fix it yourself before the IRS contacts you.
Missed it for years? How to catch up
The IRS tells people who haven't filed, aren't under investigation, and haven't been contacted about it to file the late FBARs as soon as possible. When you file late, FinCEN asks you to pick a reason from the drop-down list or choose "Other" and write a short explanation.
| Your situation | Likely route |
|---|---|
| You reported all foreign income (such as bank interest) and paid the tax, but missed the FBAR | File the late FBARs with an explanation, following FinCEN's late filing guidance |
| You didn't report foreign interest or income, and it wasn't willful | The Streamlined Domestic Offshore Procedures may fit: amend the last 3 years of returns, file FBARs for the last 6 years, and pay a 5% penalty on the highest combined balance of your foreign assets in that period |
| You've received an IRS letter or are under examination | Don't handle it alone; speak to a tax attorney right away |
Details for US residents are on the IRS streamlined procedures page. If a letter has already arrived, read our guide to official letters from the IRS and USCIS.
Common mistakes
- Using the year-end balance. The test is the highest balance on any day.
- Listing only the biggest account. Once the total passes the threshold, every account goes on the form.
- Forgetting "dormant" accounts: an old salary account, your child's account, an unmatured savings certificate.
- Ignoring signature authority over a parent's account.
- Using an unofficial exchange rate instead of the Treasury year-end rate.
- Thinking the FBAR is a tax. It is a disclosure. Interest you earn abroad, however, is income you should report.
- Moving money out to "avoid" the report. The peak balance during the year still counts for that year.
What next?
Set a yearly reminder in March to download statements from your accounts abroad, and keep them in one folder for five years. If you are bringing savings over, open a suitable local account first with our guide to opening a bank account in the US, and compare costs in our guide to sending money from the USA.
If your case is complicated, such as a company abroad, an inheritance, or many unfiled years, work with a CPA or Enrolled Agent who handles foreign accounts regularly.
Frequently asked questions
Do I owe tax on my Egyptian bank account because I filed an FBAR?
No. The FBAR is a disclosure, not a tax. Interest or other income those accounts earn may, however, be income you need to report on your US tax return.
Is the $10,000 threshold per account or combined?
Combined. If the total of all your foreign accounts exceeded $10,000 at any time during the year, you report every account.
When is the FBAR due?
April 15 of the year after the reporting year, with an automatic extension to October 15. You don't need to request it.
I have power of attorney over my father's account in Jordan. Do I report it?
If you can move the money by instructing the bank directly, you likely have signature authority and must include it once your accounts pass the threshold.
Does Form 8938 replace the FBAR?
No. The IRS says filing one does not relieve you of the other if you're required to file it. They have different thresholds and go to different agencies.
I missed the FBAR for several years. What now?
If you're not under investigation and haven't been contacted, file the late FBARs promptly with an explanation. If foreign income also went unreported, the streamlined procedures may apply; consider professional help.
Official sources we reviewed
- IRS — Report of Foreign Bank and Financial Accounts (FBAR) ↗
- IRS — Comparison of Form 8938 and FBAR requirements ↗
- FinCEN — Report Foreign Bank and Financial Accounts ↗
- FinCEN — FBAR line item filing instructions (PDF) ↗
- FinCEN — Filing late ↗
- IRS — Streamlined procedures for US taxpayers residing in the United States ↗
- IRS — Substantial presence test ↗
- IRS — Basic questions and answers on Form 8938 ↗