Foreign Financial Account holders, did you miss the April 15 filing deadline for your 2024 Foreign Bank Accounts Report (FBAR)? The automatic extended deadline is October 15th…don’t be late. Here’s what you should know.

Who Needs to File?

A U.S. person including an individual, corporation, partnership, trust, or limited liability company must file an FBAR if they meet either of the following criteria:

  • They have a financial interest in, or signature authority over, at least one financial account located outside the United States, and
  • The total value of their foreign financial accounts exceeds $10,000 at any point during the calendar year. For example, if Bank Account A holds $4,000 and Bank Account B holds $7,000, the filing threshold is met.

Filing Instructions

If your accounts meet the FBAR (FinCEN Form 114) filing thresholds, you must submit the form electronically by the due date.

Penalties for Noncompliance

Failure to file can result in significant penalties:

  • Non-willful violations: Civil penalties of up to $10,000 per violation.
  • Willful violations: Civil penalties up to $100,000 or 50% of the account balance at the time of the violation. Criminal penalties may also apply in cases of willful noncompliance.

5 Top Tips for Filers

  1. Confirm if you need to file- Review your foreign accounts carefully. You must file an FBAR if you have signature authority or a financial interest in any foreign account, and the total value exceeds $10,000 at any point during the year.
  2. Don’t miss the extended deadline- If you missed the April 15th deadline, remember the automatic extension gives you until October 15th to file. Mark your calendar and submit on time to avoid penalties.
  3. File electronically through FinCEN- Most filers submit FBARs using the FinCEN BSA E-Filing System. If someone else is filing on your behalf, you must authorize them via FinCEN Form 114a. Paper filing is only allowed if FinCEN grants an exemption.
  4. Keep thorough records- Maintain account details, including the account holder’s name, bank name and address, account number, account type, and maximum value during the year. Retain records for at least five years from the FBAR due date.
  5. Double-check account values before filing- Ensure you accurately report the maximum value of all foreign accounts during the year. Even small miscalculations can trigger filing requirements or cause delays, so verify balances carefully in your records before submitting.

FAQs- October 15 Deadline

  1. Does the One Big Beautiful Bill Act (OBBBA) impact the FBAR at all? No, rules remain the same under OBBBA. However, there are some other notable changes to international tax law. Check out our blog, The OBBBA Shifts International Tax Law.
  2. Do I still need to file if I don’t owe U.S. income tax this year? Yes. The FBAR filing requirement is based on foreign account values, not whether you owe or file a U.S. income tax return.
  3. What happens if I miss the October 15 deadline? Missing the extended deadline can result in penalties and, in cases of willful noncompliance, potential criminal penalties.
  4. Can my accountant or tax preparer file the FBAR for me? Yes. You must authorize them to do so by filing FinCEN Form 114a, Record of Authorization to Electronically File FBARs.