FBAR
Filed Accurately and On
Time
Every U.S. person with foreign financial accounts whose aggregate value exceeded $10,000 at any point during the calendar year is required to file an FBAR with FinCEN. Manay CPA identifies every account that must be reported and files your FBAR before the deadline every year.
- FBAR Preparation and Filing for U.S. Persons with Foreign Accounts
- Multi-Year FBAR Filing and Streamlined Procedures for Prior Non-Filers
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On-Time Annual FBAR Filings
For us, FBAR compliance is one of the most consequential annual filing obligations carried by U.S. persons with foreign financial accounts — and one of the most penalized when missed. The penalties for a willful failure to file can reach the greater of $100,000 or 50 percent of the account balance per violation per year. Manay CPA manages every FBAR obligation so no account is missed and no deadline is late.
Total FBAR Account Verification
The FBAR — FinCEN Form 114, Report of Foreign Bank and Financial Accounts — must be filed by every U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts if the aggregate maximum value of all such accounts exceeded $10,000 at any point during the calendar year. The $10,000 threshold is an aggregate threshold — not a per-account threshold. If you have two foreign accounts each with a balance of $6,000, the $10,000 aggregate threshold is exceeded and both accounts must be reported. Failure to file an FBAR can result in severe civil penalties that start at $10,000 per violation, even if the omission was completely unintentional. Our comprehensive review process ensures that every account—including those where you hold signature authority without direct ownership—is properly disclosed to protect you from these aggressive enforcement actions.
Foreign financial accounts that must be reported include foreign bank accounts, foreign brokerage accounts, foreign mutual funds, and foreign accounts in which a U.S. person has a financial interest — including accounts held by a foreign entity in which the U.S. person has more than 50 percent ownership. Accounts over which a U.S. person has signature authority — such as an employee who has signatory authority over a corporate account — must also be reported even if the person has no financial interest in the account.
Manay CPA identifies every account in your profile that meets the FBAR reporting criteria — analyzing financial interest, signature authority, and aggregate value — and files FinCEN Form 114 through the BSA E-Filing system before the April 15 deadline with the automatic extension to October 15. We coordinate your FBAR filing with your Form 8938 and income tax return to ensure all foreign account disclosures are consistent across every reporting channel.
The High Cost of FBAR Non-Compliance
The FBAR civil penalty regime is intentionally severe. A non-willful failure to file carries a penalty of up to $10,000 per violation — and the IRS and courts have interpreted violation to mean per account per year in many cases. A willful failure — which the IRS defines as a knowing or reckless disregard of the FBAR obligation — carries a penalty of the greater of $100,000 or 50 percent of the highest balance in the unreported account for each year of willful non-compliance. Criminal penalties for willful violations include fines of up to $500,000 and imprisonment of up to ten years. Manay CPA manages FBAR compliance proactively so these consequences never arise.
Guaranteed Annual FBAR Compliance
Manay CPA reviews your complete foreign account profile every year — identifying every account that triggers a reporting obligation, confirming the maximum annual balance for each reportable account, and filing FinCEN Form 114 with complete and accurate information for every required disclosure before the applicable deadline.
Our team understands the full scope of what constitutes a foreign financial account for FBAR purposes — including accounts that many taxpayers do not realize are reportable, such as foreign pension accounts, foreign life insurance with cash value, accounts in which the taxpayer has a financial interest through a foreign entity, and accounts over which only signature authority exists.
File Your Return the Right Way
The U.S. tax code is far more complex than a basic W-2 and standard deduction. Self-employment, rentals, capital gains, and foreign assets each carry unique reporting rules. A single oversight or misclassified item costs you real money—either in overpaid tax or in penalties assessed later.
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Table of Contents
The $10,000 FBAR Threshold Is Aggregate Across All Foreign Accounts Not Per Account
The most common misunderstanding about FBAR is the nature of the $10,000 threshold. The threshold is not applied account by account — it is the aggregate maximum value of all foreign financial accounts combined during the calendar year. If the aggregate maximum value exceeds $10,000 at any point — even briefly — every foreign account must be reported on the FBAR regardless of the individual balance of each account.
This means that a U.S. person with three foreign accounts each maintaining balances well below $10,000 may still be required to file an FBAR if the aggregate maximum value of all three accounts at any point during the year exceeded $10,000. Manay CPA calculates the aggregate maximum value for every client’s foreign account profile and determines the FBAR filing requirement based on the correct aggregate threshold analysis.
Reporting Signature Authority Without Ownership
Many U.S. persons who have signature authority over foreign accounts — employees of multinational corporations, officers of foreign subsidiaries, or individuals authorized to operate accounts on behalf of foreign entities — are required to file FBARs for those accounts even if they have no personal financial interest in them.
The signature authority FBAR obligation is widely unknown among the employees and officers who carry it — and the penalty for a non-willful failure applies regardless of whether the person had any financial benefit from the account. Manay CPA identifies every signature authority obligation in your professional profile and includes every qualifying account in your annual FBAR filing.
Fixing Past Non-Compliance with Streamlined Filing
U.S. taxpayers who failed to file required FBARs in prior years on a non-willful basis — meaning the failure was due to negligence, inadvertence, or a misunderstanding of the law — can use the IRS Streamlined Filing Compliance Procedures to file late FBARs with significantly reduced penalties compared to what would apply outside the program.
The streamlined domestic program imposes a 5 percent miscellaneous offshore penalty on the highest aggregate balance of unreported foreign accounts. The streamlined offshore program — available to qualifying non-resident U.S. taxpayers — imposes no penalty. Both programs require the filing of FBARs for the six most recent years and amended tax returns for the three most recent years. Manay CPA manages the complete streamlined filing process — assessing eligibility, preparing all required filings, and submitting the non-willfulness certification on your behalf.
Frequently Asked Questions
Who is required to file an FBAR?
Every U.S. person — including citizens, resident aliens, and certain non-resident aliens — who has a financial interest in or signature authority over one or more foreign financial accounts must file an FBAR if the aggregate maximum value of all such accounts exceeded $10,000 at any point during the calendar year. U.S. persons include individuals as well as U.S. entities — corporations, partnerships, limited liability companies, trusts, and estates — that have foreign financial accounts above the threshold.
What is the FBAR filing deadline?
The FBAR is due on April 15 of the year following the calendar year being reported — the same date as individual income tax returns. An automatic extension to October 15 is available without filing any extension request. The FBAR is filed electronically through FinCEN’s BSA E-Filing system at fincen.gov — it is not filed with the IRS or included with the income tax return. Manay CPA files every client’s FBAR through the BSA E-Filing system and retains the confirmation receipt as part of the compliance record.
What types of accounts must be reported on the FBAR?
Foreign financial accounts reportable on the FBAR include foreign bank accounts, foreign brokerage accounts, foreign mutual fund accounts, foreign accounts held in a retirement or pension fund, foreign life insurance with a cash surrender value, and any other foreign financial account maintained at a foreign financial institution. Accounts in which the U.S. person has a financial interest through a foreign entity — if they own more than 50 percent of the entity — are also reportable. Accounts over which the U.S. person has only signature authority — with no financial interest — are separately reportable.
What are the penalties for not filing an FBAR?
Non-willful failure to file an FBAR carries a penalty of up to $10,000 per violation. Willful failure carries a penalty of the greater of $100,000 or 50 percent of the highest balance in the unreported account — per violation per year. Courts have assessed these penalties on a per-account-per-year basis in some cases, making the total exposure for multi-year willful non-compliance across multiple accounts extremely significant. Criminal penalties for willful violations include fines up to $500,000 and imprisonment up to ten years. Acting through the streamlined procedures before the IRS identifies a non-willful failure is the most effective way to resolve prior non-compliance.
Can Manay CPA help me file FBARs for prior years that I missed?
Yes. If you have foreign financial accounts that should have been reported on FBARs in prior years and were not, Manay CPA assesses whether the failures qualify as non-willful — which would allow use of the streamlined filing procedures with significantly reduced penalties — and manages the complete catch-up process. This includes preparing FBARs for all required prior years, filing amended tax returns where income from the foreign accounts was not properly reported, and preparing and submitting the non-willfulness certification required for the streamlined program.
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