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28 thoughts on “What Is The FinCEN Form 114 (Report of Foreign Bank and Financial Accounts)?

  1. My brokerage account is located in the United States (NYC). Several of the stocks are foreign companies but currently I have no obligation to report since the stock/fund is in street name in the U.S..

    1) What would be my F114 obligations if I Direct Register these holdings?
    2) What would be my F114 obligations if I take possession of actual stock Certificates?


    1. Hi Jenn, a joint FBAR can be filed to report joint accounts irrespective of the filing status used on the individual tax return (Form 1040). Below are the specific instructions for the FinCen Form 114 on this topic:

      Certain Accounts Jointly Owned by Spouses.

      The spouse of an individual who files an FBAR is not required to file a separate FBAR if the following conditions are met:

      (1) all the financial accounts that the non-filing spouse is required to report are jointly owned with the filing spouse;

      (2) the filing spouse reports the jointly owned accounts on a timely filed FBAR electronically signed (PIN) in Item 44; and

      (3) the filers have completed and signed Form 114a, “Record of Authorization to Electronically File FBAR’s” (maintained with the filers’ records).

      Otherwise, both spouses are required to file separate FBARs, and each spouse must report the entire value of the jointly owned accounts.

      See instructions for specific items, Part III, Items 25- 33.

      Best regards,



    CA.CA. Vallabhdas Raichura

    June 9, 2014.

  3. Hello

    I lived in US as resident for half of last year> When I moved here, my foreign banks transfered my accounts to new accounts with new numbers and address. So I essentially have 2 account numbers during the year for the same account.

    In my FINCEN forms do I put information on both accounts with the maximum value of each of them? Will I have tax consequences or issues – b/c they are essentially a single account to me – only with a different account number at the end of the year than the beginning? The original account was closed up on transfer

  4. Hi, I am a non-resident to USA and worked in USA for 175 days. As I am a resident of other country(non US) where in I am having my salary, saving & brokerage accounts. With respective to US these accounts are Foregin Bank a/cs.. I am curious whether I have to file FBAR or not? now I am not in US and residing in my home country. Please suggest.

    1. Hi Venkat, if for the tax year in question you met the test to be classified as a resident (for tax purposes), an FBAR would be required for that tax year. In essence, any tax year you are classified as a resident (for tax purposes) you are considered to be a U.S. person for being subject to the FBAR filing requirements.

      Best regards,

  5. How do you report when you have more than one account, on Form 114?
    IRS instructions, in my opinion, is not very clear on this. Example: How do you report when you have two separate bank accounts, both over $10,000 and you also have a separate brokerage account with value over $10,000. Do you file a separate Form 114 for each?

  6. I am U.S. citizen. I have a stock brokerage account with a large stock broker. One of the stocks in my portfolio has a market value of $22,000. This stock is for a foreign corporation located in Canada. Should I file the FinCEN Form 114 and report the value of this foreign stock which my broker is holding in my account?
    Thank you,

    Joel Anderson

    1. Hi Joel, assuming that the stock brokerage account is a foreign brokerage account, the high value of all of your holdings in your foreign securities/brokerage account would need to be reported on the FinCEN Form 114.

      Best regards,

      1. No Randall, the brokerage account is located in the United States. Only the one stock within the brokerage account is a foreign security.

        Does that one security have to be reported on the FinCEN Form 114?

        Thanks for your help,

        Joel Anderson

  7. Hi,

    I have bank accounts abroad back home, and I just came to learn about FBARs this year. Is it required for us to report our FBARs for all my previous years in the US (I have been in the US for about twelve years…)? If so, will I be issued a penalty for delinquent filing of my previous years if they are now retroactively filed correctly?

    Thanks for your help!

    1. Hi Albert, the FBAR is required to be filed for all years that you are considered a U.S. person and have an aggregate value of more than $10,000 in foreign financial accounts. The penalties can be quite severe depending on the value of your foreign accounts and the specifics of your situation as it relates to the delinquency. My recommendation would be to certainly file the delinquent FBARs and to seek the advice or legal review from an attorney depending on the nature of the delinquency and value of the accounts held. My firm can assist you with the preparation of your delinquent FBARs and we work with an attorney that can provide you with a legal review of your filing options so that you can make a decision in your best interest in regards to your chosen method of filing the delinquent FBARs.

      Best regards,

  8. When I download the FBAR form on BSA Efiling site the following issues arise:
    1) I could not download using Chrome Browser so had to install Internet Explorer.
    2) When adding my address, It appears as though only American Zip codes are allowed to be entered – ie the PDF form is locked with validation which discriminates and requires only American Post Codes. Evne though I selected Country = GB (United Kingdom).
    Anyone else living abroad noticing the same issue?
    Real Shame that American IRS does not seem to undertake due diligence in testing the e-filing process for those citizens abroad who are left to feel abandoned like I do.
    At American Embassy in London I was told you have to “find out the solution to Tax filing on your own” – real shame ;-<

    1. Hi Nick, indeed these compliance processes are for a lack of a better term “a pain in the butt”. Since compliance is a given, your options are to navigate oneself through the process of self-preparing and self-educating (which can be a struggle and frustrating and ultimately left with some uncertainty as to whether the filings/compliance is accurately filed) or hiring a professional that will be your expert guide through compliance with your returns.

      Best regards,

  9. If I have a 5% interest (100k) in a foreign project valued at 2 million would I need to file an FBAR? I have been issued shares in a document from that foreign country?

    1. Your interest in a foreign entity by itself would not necessitate the filing of an FBAR. However, depending on the value of the interest during the year (and end of year) along with other specified foreign financial assets held during the year, you may meet the filing requirements for the Form 8938.

      Best regards,

  10. For taxpayers filing their 6-yr delinquent FBARs, do they file them on paper or electronically? If latter, how do they submit the reasonable cause letter? Also, is there a FinCEN Form 114 in pdf format? Thanks.

    1. Hi Alice, FBARs (for all years) are required to be filed electronically using the new BSA FinCen Form 114. The form is available for input into a pdf form that is electronically filed.

      Best regards,

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