Do I Have to File an FBAR for My US Company's Foreign Accounts?

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Do I Have to File an FBAR for My US Company's Foreign Accounts?

By Andres Platts · August 13, 2026 · 4 min read

Quick answer

If your US company can control foreign accounts holding over $10,000 combined at any point in the year, it files an FBAR. The deadline is October 15.

If your US company has signature authority over, or a financial interest in, foreign financial accounts whose combined value exceeded $10,000 at any single moment during the year, it must file an FBAR. The final deadline for the 2025 calendar year is October 15, 2026.

The threshold catches more owners than they expect, because it is measured across all accounts at their highest point, not on the balance you happen to hold today.

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What Exactly Is an FBAR?

The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. It is not a tax return and it does not calculate anything you owe. It is a disclosure, filed with the Treasury's Financial Crimes Enforcement Network rather than with the IRS, declaring which foreign accounts you or your US entity can reach. No payment accompanies it, and filing one does not by itself create a tax liability.

Does My US Company File One, or Do I Personally?

Potentially both, and they are separate filings. A US entity files in its own right when it holds or controls qualifying foreign accounts. You may also have a personal obligation if you hold foreign accounts individually, or if you have signature authority over the company's accounts. Owners frequently assume the company filing covers them personally. It does not.

How Is the $10,000 Threshold Actually Measured?

It is an aggregate high-water mark, not a per-account balance and not a year-end figure. Add together the maximum value each foreign account reached at any point in the year. If that combined total crosses $10,000 even for a single day, every one of those accounts is reportable, including the ones holding very little. A company running three modest operating accounts abroad can cross the line without any single account looking significant.

It is a disclosure, filed with the Treasury's Financial Crimes Enforcement Network rather than with the IRS, declaring which foreign accounts you or your US entity can reach.
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The $10,000 test is the combined highest value of all foreign accounts at any moment in the year. Cross it once and every foreign account becomes reportable, not just the large ones.

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When Is the Deadline, and Is the Extension Automatic?

The FBAR is nominally due April 15, but the extension to October 15 is granted automatically. You do not request it, you do not file a form for it, and there is no penalty for using it. That is unusual, and it is worth knowing precisely, because the neighbouring deadline behaves differently: Form 5472 with its pro-forma Form 1120 also lands on October 15, but only for filers who submitted Form 7004 back in April. One extension is automatic. The other had to be claimed months ago.

What Happens After October 15?

October 15 is the end of the road for the FBAR. There is no second extension and no further grace period. That makes it different in character from deadlines that can be pushed again, and it is the reason we treat early October as a hard internal cutoff for clients with foreign accounts rather than a soft target.

What Are the Consequences of Not Filing?

Penalties are assessed per account and per year, and they escalate sharply where the failure is judged wilful rather than inadvertent. The more common problem we see is not a single missed year but a pattern: an owner who did not realise the obligation existed discovers several unreported years at once. The remedies for that situation are meaningfully better when you approach them before being contacted, which is the practical argument for resolving it now rather than after a notice arrives.

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Which Accounts Count as Foreign?

The test is where the account is located, not what currency it holds or which bank's name is on it. An account at a foreign branch of a US bank is foreign for these purposes. A US-dollar account held abroad is foreign. Beyond ordinary bank accounts, the definition reaches securities accounts, certain insurance and annuity products with cash value, and accounts you do not own but can direct. That last category, signature authority without ownership, is the one most often overlooked.

How Prodezk Handles This

We review which of your accounts and entities actually meet the definition, file the FBAR alongside the rest of the annual calendar, and keep the personal and corporate obligations separate so neither is quietly assumed to cover the other. If several years are unfiled, we will tell you plainly what the options are before anything is submitted. Speak with an advisor if you are not certain where you stand.

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