Foreign account reporting
Report every account once, correctly, on the right form.
The FBAR is a report of foreign financial accounts filed with FinCEN, not the IRS. It is required when the combined highest balances of all your non-US accounts exceed US$10,000 at any point in the year, even briefly. Form 8938 is filed with your tax return when specified foreign financial assets exceed higher thresholds. Many people need both; the forms overlap but are not the same.
Who this is for
- Anyone with UK current, savings, ISA, investment or pension accounts and a US filing obligation
- People who have received a FATCA letter from their UK bank
- Those with signature authority over a UK business or trust account
What we prepare
- Threshold check
- Across every account, including joint accounts, ISAs, premium bonds, pensions where reportable, and accounts you can sign on but do not own.
- FinCEN Form 114
- Maximum values converted at the Treasury year-end rate and filed electronically through the BSA E-Filing system.
- Form 8938
- For people living abroad: US$200,000 at year end or US$300,000 at any time (US$400,000 / US$600,000 for joint filers).
- Pensions and ISAs
- A defined contribution pension pot, a defined benefit scheme and an ISA are each treated differently on the two forms. We document the approach taken.
- Late FBARs
- Delinquent FBAR submission procedures where returns were otherwise complete, or Streamlined where they were not.
Why it is easy to get wrong
The FBAR counts the highest balance during the year, not the closing balance, and aggregates across all accounts, so several small accounts can cross the threshold together. Money transferred between your own accounts can be counted twice at its peak, which is correct for FBAR purposes even though it feels odd.
It is a disclosure form, not a tax charge. Nothing is owed on the accounts, but the penalties for not reporting are significant, which is why we treat it as part of every US return rather than an add-on.
Process
How it works
- 01
Account list
Every non-US account you hold or can sign on, with the highest balance in the year.
- 02
Written quote
Usually quoted together with your US return.
- 03
Preparation
Thresholds checked, values converted, forms prepared.
- 04
Your review and filing
You confirm the account list in the portal; we file the FBAR electronically and attach Form 8938 to the return.
FAQ
Questions we are asked
What is the FBAR deadline?
15 April, with an automatic extension to 15 October. No extension request is needed.
Do I report my UK pension on the FBAR?
Often yes for a defined contribution pot or SIPP that you can direct; the position for a defined benefit scheme and the state pension is different. We state the treatment we have applied so you can see it.
FBAR or Form 8938, or both?
They have different thresholds, different definitions of what counts, and go to different agencies. Many people living abroad need the FBAR but not Form 8938 because the 8938 thresholds abroad are higher. We check both every year.
Written by the US UK Expat Tax advisory team. Last reviewed 7 November 2026
Primary sources checked
General information, not personal tax advice. Rules and thresholds change; we confirm the position for your facts before any work.
Get started
Tell us your situation
Where you live, which years are involved, what has been filed, and every source of income in each country. We reply by email within two working days with what is needed and a written fee. No free consultations, and no work starts before you have the quote.