If you’re an American living in Hong Kong, you might wonder how overseas bank account reporting works. Good news, the process is simpler than it sounds. Per the Bank Secrecy Act, you must report certain foreign financial accounts each year by filing FinCEN Form 114, known as the FBAR. You meet the filing threshold when the combined value of those overseas accounts tops $10,000 at any point during the calendar year.

Key idea: You need to submit an FBAR if your foreign holdings exceed $10,000 in total.

Understand reporting requirements

Who must report

US persons must file an FBAR if they have foreign accounts over $10,000 in combined value. That includes:

  • Citizens and resident aliens
  • Corporations, partnerships, trusts, and estates
  • Anyone with signature authority or other authority over a foreign account

Which accounts count

Most accounts held at institutions outside the US require reporting. Common examples are:

  • Bank accounts and savings accounts
  • Brokerage accounts and mutual funds
  • Trusts and other collective investment vehicles

Exceptions include retirement plans such as IRAs and tax-qualified retirement accounts (these are not FBAR reportable). You can read more about foreign bank account reporting rules.

Prepare FBAR submission

Collect required details

Before you file, gather:

  • Account number and name on the account
  • Financial institution name and address
  • Maximum account value during the year (convert to US dollars using the Treasury exchange rate on December 31)
  • Your recordkeeping documentation (keep it for five years from the FBAR due date)

File electronically

You must submit your FBAR online through FinCEN’s BSA E-Filing System. Key steps:

  1. Log in or register at the FinCEN BSA E-Filing portal
  2. Complete FinCEN Form 114 for each filing party
  3. If someone else files for you, submit FinCEN Report 114a to authorize them
  4. Meet the April 15 deadline or take the automatic extension to October 15 (no separate request needed)

This report is separate from your federal tax return. For more on disclosure requirements, see foreign-account-disclosure-requirements.

Manage penalties and relief

Civil and criminal penalties

Failing to file or filing late can trigger significant penalties:

  • Non-willful violations: up to $10,000 per violation
  • Willful violations: the greater of $100,000 or 50 percent of the account balance at time of violation, plus possible criminal charges (up to $250,000 and five years in prison)
    (maximum penalties adjust annually for inflation)

Late filing programs

Don’t worry if you’ve missed a deadline – relief options exist:

  • Delinquent FBAR Submission Procedures let compliant taxpayers file late without penalty, if no unreported income exists
  • The Streamlined Foreign Offshore Compliance Program helps those with non-willful failures catch up on FBARs and tax returns

Consult a tax professional to determine which path works best for you.

Plan next steps

Work with American Pacific Tax

At American Pacific Tax, we guide American expats through overseas bank account reporting. We’ll help you prepare accurate FBARs and stay compliant with US regulations. Reach out for a free consultation on your foreign account compliance or expat tax return preparation needs.

Helpful resources

You’ve got this – staying on top of your overseas reporting helps you avoid penalties and focus on life abroad.

FAQs

  1. What is an FBAR and who needs to file one?
    The FBAR (FinCEN Form 114) is an annual report for US persons with foreign financial accounts exceeding $10,000 in combined value at any time during the calendar year.
  2. How do I submit an FBAR electronically?
    File through FinCEN’s BSA E-Filing System. You can file directly or authorize someone via FinCEN Report 114a. This is separate from IRS e-filing.
  3. What are the penalties for missing the FBAR deadline?
    Late or non-filing can lead to civil penalties up to $10,000 per non-willful violation. Willful violations carry fines up to $100,000 or 50 percent of the account balance, plus potential criminal charges.