Navigating IRS foreign account disclosure can feel intimidating, especially when you’re juggling life in Hong Kong and keeping up with U.S. rules. A 2025 IRS update notes that willful FBAR penalties can reach $165,353 or half your account balance per violation. Good news, meeting your U.S. expat reporting duties doesn’t have to feel overwhelming.

With clear steps and the right support, you can handle your U.S. expat disclosure smoothly.

Track your accounts abroad

Since 1970, the Bank Secrecy Act has required U.S. persons to report foreign financial accounts if the total value tops $10,000 at any point in the year. That includes bank, brokerage, mutual fund, or other accounts held outside the United States.

  • Note each account’s maximum value, account number, type, and the institution’s name and address
  • Keep copies of statements and account agreements for at least five years

You may also need to meet additional FATCA reporting thresholds if your overseas assets exceed certain values. For a full list of what counts and when to report, see our guide to overseas bank account reporting.

Prepare and file on time

Your FBAR (FinCEN Form 114) is due April 15, with an automatic extension until October 15 if you miss the first deadline. You file electronically through FinCEN’s BSA E-Filing System, not with your federal tax return.

  1. Gather details on each foreign account
  2. Log in to FinCEN’s portal before April 15
  3. Submit Form 114 by the extended date if needed

If you don’t have all your records by October 15, file as complete a report as possible, then amend when the rest arrives. Spouses can file one joint FBAR by signing Form 114a.

See our overview of foreign account disclosure requirements for more on timing and formats.

Understand penalty risks

Civil and criminal penalties can apply to FBAR violations. For non-willful failures, civil fines can reach $13,481 per violation (adjusted for inflation). Willful omissions are more serious, with penalties up to $165,353 or 50 percent of the account balance per violation. Criminal sanctions may include fines and up to five years in prison.

A 2024 Treasury report found that reasonable-cause filings (when you explain a valid reason for lateness) usually avoid penalties. You’re not alone if you’ve fallen behind. Relief programs like the Streamlined Foreign Offshore Compliance Program or Voluntary Disclosure Practice can help you catch up without harsh fines. Learn more about staying on the right side of foreign account compliance.

Get professional support

Handling U.S. expat tax rules from Hong Kong can be tricky. We at American Pacific Tax help you:

You deserve clear guidance, not complexity. Our team combines deep data awareness with a friendly, step-by-step approach so you can focus on life in Hong Kong, not endless forms.

Recap and next steps

  1. Track every foreign account and record its high-water mark.
  2. File your FBAR by April 15 (October 15 extended deadline).
  3. Explore relief options if you missed a deadline or face penalties.
  4. Consider expert help to avoid mistakes and ease your compliance.

Choose one action today, even if it’s just gathering your statements. You’ve got this, and American Pacific Tax is here to guide you.

Your top FAQs

Do I need to file FBAR from Hong Kong?

Yes, if you’re a U.S. person (citizen or resident) and your combined foreign accounts exceed $10,000 at any time, you must file. See our notes on overseas bank account reporting for details.

Can I file FBAR with my tax return?

No, FBAR goes through FinCEN’s e-file system, not the IRS. You can work with our expat tax return preparation team to align both filings.

What if I missed the deadline?

File as soon as you can. You have until October 15 automatically. If you still face penalties, look into reasonable-cause relief and streamlined compliance. Visit our guide on foreign bank account reporting rules to learn more.