Pillar Guide
FBAR Complete Guide: Foreign Account Reporting for Global Founders
If you hold financial accounts outside the US — including fintech platforms like Wise, Revolut, or N26 — you may have FBAR filing obligations with FinCEN. This guide maps the structural landscape.
What is FBAR?
FBAR (Report of Foreign Bank and Financial Accounts) is a filing requirement administered by FinCEN — not the IRS. US persons who hold foreign financial accounts with an aggregate value exceeding $10,000 at any point during the calendar year are required to file FinCEN Form 114.
The key word is aggregate. If you have $6,000 in a Wise account and $5,000 in a Revolut account, the combined $11,000 triggers the obligation — even though neither account individually exceeds the threshold.
Who Needs to File?
Any US person — citizens, permanent residents, and those meeting the substantial presence test — with signature authority or financial interest in foreign accounts. This includes accounts you may not think of as “foreign”: Wise multi-currency balances, Revolut accounts, TransferWise borderless accounts, and foreign brokerage accounts.
The Penalty Structure
Non-willful violations carry penalties up to $10,000 per account per year. Willful violations can reach the greater of $100,000 or 50% of the account balance. There is a 6-year statute of limitations for non-willful violations, and no statute of limitations for willful violations.
The Structural Pattern
In diagnostic after diagnostic, the same pattern emerges: founders who are fully compliant on their income tax filings have no awareness of FBAR. The obligation exists in a separate regulatory channel that most CPAs — particularly those focused on domestic small business — do not surface.
Related Analysis
Explore these structural insights for deeper context:
FBAR for Digital Nomads: The $10K Threshold Trap
How fintech accounts like Wise and Revolut trigger FBAR obligations most founders miss.
Tax Residency Is Not Where You Think
Why physical presence alone does not determine your tax obligations.
The Documentation Gap: What Authorities Actually See
The difference between what you think you have documented and what regulators find.
Tax Residency Tie-Breaker Rules
When two countries both claim you as a tax resident, treaty tie-breaker rules determine the outcome.
When Routine Shortcuts Become Permanent Evidence
How small operational shortcuts compound into structural risk over time.
Map your FBAR exposure
The META Risk Profile identifies foreign account reporting gaps as part of the Tax and Accountability dimensions.
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