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FBAR & FATCA reporting, done before it becomes a penalty.

Two separate regimes require Americans to disclose non-US accounts: the FBAR filed with FinCEN and Form 8938 filed with your return. The thresholds differ, the definitions differ, and the penalties for silence are among the harshest in the code.

Figures relate to tax year 2025 (US) · 2025-26 (UK)

  1. The $10,000 trigger is lower than it sounds

    The FBAR threshold is aggregate — every current account, savings account, ISA and pension you can sign on, measured at each account's highest point in the year. An ordinary London salary plus a deposit-sized savings balance crosses it easily.

    We identify every reportable account, aggregate the maximum balances correctly, and file the FBAR alongside Form 8938 where your totals require it.

    • FinCEN Form 114 (FBAR) preparation and filing
    • Form 8938 where FATCA thresholds are met
    • Joint accounts and signature-authority accounts handled
    • Delinquent FBAR procedures where filings were missed
  2. Missed years are usually fixable

    If you have never filed an FBAR, the answer is almost never to start quietly filing this year's. The delinquent-FBAR procedures and the Streamlined programme exist precisely for this, and used correctly they remove the penalty exposure entirely.

  3. A process built for messy account histories

    The hard part of account reporting is rarely the form — it is reconstructing the list: the dormant account from a first job, the joint account with a parent, the pension from three employers ago. Our intake walks through every category so nothing surfaces later.

    Balances are converted at the correct Treasury rates, maximums are evidenced from statements rather than guessed, and the working papers are kept so next year's filing takes a fraction of the time.

    • Structured account discovery, category by category
    • Statement-evidenced maximum balances
    • Correct Treasury year-end conversions
    • Working papers retained for future years

Questions, Answered.

What clients ask about fbar & fatca reporting

Which accounts count?

Bank accounts, most investment and brokerage accounts, certain pensions and some insurance products with a cash value.

Accounts you do not own but can control - a business account, or a relative's account you hold signature authority over - can also be reportable.

What if the account is joint with a non-US spouse?

It is still reportable, and generally at its full value rather than your share, which surprises people.

The reporting obligation follows the US person's access to the account rather than their beneficial share of it.

Does filing an FBAR increase my chance of an audit?

Filing correctly is not what draws attention. What draws attention is the gap between accounts a foreign bank reports under FATCA and what you disclosed.

Banks report to the IRS independently, so silence is more visible than a filing.

What triggers an FBAR?

The combined high balance of all your non-US financial accounts crossing $10,000 at any point in the year. It is aggregate, so several small accounts can cross the line together.

It also counts the highest balance during the year rather than the closing balance, so money that passed through briefly still counts.

Is FBAR a tax?

No. It is a disclosure filed with FinCEN, not the IRS, and nothing is owed on the accounts themselves.

The reason it matters is the penalty regime for not filing, which is severe and entirely avoidable.

How is FATCA different from FBAR?

FATCA reporting is made on Form 8938 with your tax return and covers a broader class of specified foreign financial assets. FBAR is a separate FinCEN filing covering accounts.

The thresholds differ and depend on filing status and where you live, so plenty of people owe one and not the other - and plenty owe both.

What if I have missed several years?

Delinquent FBARs can usually be brought current, and where the omission was non-wilful the Streamlined programme covers six years of them without penalty.

Filing them quietly outside a formal programme is generally the wrong move, because it forfeits the protection those programmes give.

Next Step.

Tell us what you hold — the scope and a fixed fee follow in writing.

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