US Expat Tax · FBAR Filing
FBAR filing for Americans in the UK
If you are a US person living in the UK and the combined value of your non-US financial accounts exceeded US$10,000 at any point in the year, you must file an FBAR (FinCEN Form 114) with the US Treasury. It is an information report, not a tax — filed separately from your tax return, due 15 April with an automatic extension to 15 October. We handle current-year FBARs and help you catch up on missed years.
The FBAR — the Report of Foreign Bank and Financial Accounts, filed on FinCEN Form 114 — catches a lot of Americans in the UK by surprise. The most important thing to understand is that it is not a tax form. You do not pay anything when you file it; it is an information report filed with the US Treasury’s Financial Crimes Enforcement Network (FinCEN), separately from your federal tax return.
You generally must file if you are a US person — a US citizen, including dual citizens, a green card holder, or a US tax resident — and the combined value of your foreign financial accounts exceeded US$10,000 at any point during the calendar year. The threshold is an aggregate figure, not per account, and it is measured at the highest balance each account reached during the year.
For Americans in the UK, the accounts that trigger this are usually ordinary ones: current and savings accounts, cash ISAs, UK investment accounts, and many UK pensions. Joint accounts held with a non-US spouse, and accounts you can merely operate — such as an employer or family account — can count too.
FBAR at a glance
- Form
- FinCEN 114
- Threshold
- $10,000 aggregate
- Measured
- Highest balance, any point
- Deadline
- 15 Apr → 15 Oct
- Filed with
- US Treasury (FinCEN)
- A tax?
- No — information report
Who needs to file an FBAR
- US citizens living in the UK, including "accidental Americans" and dual citizens
- Green card holders and others who are US tax residents
- Anyone with UK accounts — current, savings, ISAs, investments — over $10,000 combined
- People with signature authority over an employer, family or business account
- Those who hold joint UK accounts with a non-US spouse
- US persons who have missed FBARs in prior years and need to catch up
When it is required, and the deadline
The FBAR is an annual report covering the previous calendar year. It is due on 15 April, with an automatic extension to 15 October — you do not need to request the extension or file any form to receive it. It is submitted electronically through the BSA E-Filing System, never with your tax return.
Common mistakes we see
The most frequent errors are assuming only large accounts count (the $10,000 test is the combined total, so several small accounts can cross it); forgetting accounts you only have signature authority over; overlooking accounts that were closed mid-year; and assuming that filing a US tax return somehow covers the FBAR — it does not, as the two are entirely separate filings.
FBAR vs Form 8938 (FATCA)
These are the two most commonly confused filings. Many Americans in the UK have to file both, because they serve different agencies and have different thresholds.
| FBAR (FinCEN 114) | Form 8938 (FATCA) | |
|---|---|---|
| Filed with | US Treasury (FinCEN) | IRS, with your tax return |
| Threshold | $10,000 aggregate, any point in year | Higher; varies by status & residence |
| How it is filed | Electronically via BSA E-Filing | Attached to Form 1040 |
| Deadline | 15 Apr (auto-extends to 15 Oct) | With your return (incl. extensions) |
| Counts signature authority | ||
| Many UK-based Americans file | Yes | Often both |
FBAR (FinCEN 114)
- Filed with
- US Treasury (FinCEN)
- Threshold
- $10,000 aggregate, any point in year
- How it is filed
- Electronically via BSA E-Filing
- Deadline
- 15 Apr (auto-extends to 15 Oct)
- Counts signature authority
- Many UK-based Americans file
- Yes
Form 8938 (FATCA)
- Filed with
- IRS, with your tax return
- Threshold
- Higher; varies by status & residence
- How it is filed
- Attached to Form 1040
- Deadline
- With your return (incl. extensions)
- Counts signature authority
- Many UK-based Americans file
- Often both
How we handle it
From uncertainty to filed, without the stress
Assess
We confirm whether you need to file, for the current year and any missed years, and which accounts are reportable.
Gather
We help you identify every reportable account and its highest balance, converted to US dollars correctly.
Prepare
We prepare the FBAR — and, where needed, Form 8938 — accurately and consistently with your tax return.
File & record
We e-file through the BSA system and give you a clean record of what was filed and when.
Behind on past years?
If you should have been filing FBARs and have not, do not simply back-file on your own. The IRS Streamlined Filing Compliance Procedures exist for non-willful taxpayers who have fallen behind and, handled correctly, can bring you current — typically three years of returns and six years of FBARs — without penalties. The right route depends on your specific facts, which is exactly why it is worth a conversation before you act.
Not sure if you even need to file? Use our free FBAR checker to walk through the triggers in under a minute.
Related areas we handle
Frequently asked questions
Any US person — a US citizen (including dual citizens living abroad), green card holder, or someone meeting the substantial-presence test, as well as US entities — who has a financial interest in or signature authority over one or more foreign financial accounts, where the combined maximum value exceeded US$10,000 at any point during the calendar year.
In total. It is the aggregate of the highest balance each foreign account reached during the year, converted to US dollars. If the combined figure crossed $10,000 at any single moment — even briefly — every foreign account must be reported, including small ones.
The FBAR is due on 15 April, with an automatic extension to 15 October. You do not need to request the extension. It is filed electronically as FinCEN Form 114 through the BSA E-Filing System, separately from your federal tax return.
Yes. If you can direct transactions on a foreign account — for example an employer, family or business account — that account can create an FBAR obligation for you once your reportable accounts cross the $10,000 aggregate, even though the funds are not yours.
They are separate filings. The FBAR (FinCEN Form 114) goes to the US Treasury’s Financial Crimes Enforcement Network and has a $10,000 aggregate threshold. Form 8938 is filed with the IRS as part of your tax return under FATCA and has higher thresholds that vary by filing status and whether you live abroad. Many Americans in the UK have to file both.
Do not simply back-file without advice. The IRS Streamlined Filing Compliance Procedures exist for non-willful filers who have fallen behind and, handled correctly, can bring you current without penalties. This is exactly the kind of situation worth a consultation before you act.
Need to file an FBAR — or catch up on missed years?
Book a confidential consultation. We'll confirm whether you need to file, for which years, and handle the whole submission.