FBAR Basics for US Persons with Indian Accounts
The FBAR, formally the Report of Foreign Bank and Financial Accounts filed on FinCEN Form 114, is a separate filing from your income tax return. It is required of US persons who have foreign financial accounts above a threshold. Many people with Indian accounts do not know it exists until a bank asks questions or an adviser reviews past returns.
Key rules at a glance
| Topic | General rule | Notes |
|---|---|---|
| Who files | US persons: citizens, green card holders and others who meet the US person definition | Residence and citizenship determine status; check your facts |
| Threshold | Combined value of all foreign financial accounts exceeds $10,000 at any time during the calendar year | It is an aggregate test, so several small accounts can add up |
| What counts | Bank accounts, brokerage and demat accounts, mutual funds, certain insurance policies with cash value, and other financial accounts | Real estate held directly is generally not an FBAR account |
| Due date | April 15 of the year after the calendar year reported, with an automatic extension to October 15 | Confirm the current FinCEN due date guidance each year |
| How to file | Electronically through the FinCEN BSA E-Filing System | Paper filing is not the normal route |
| Penalties | Civil penalties can apply for late or inaccurate filings, and can be severe, especially in cases judged willful | Past years may still be fixable; see our FAQ and consultation page |
The threshold is an aggregate test
Add together the highest balance of each foreign account during the year, converted to US dollars. If the total exceeds $10,000 at any point, you must file. Joint accounts and accounts where you have signature authority can count, even when the money is not yours. Check the threshold each year, because one large deposit can trigger a filing for a year when you thought you were under.
Currency conversion
Indian accounts are held in rupees, so each balance must be converted to US dollars. FinCEN requires the use of specified Treasury rates of exchange rather than a rate you choose. Keep a record of the balances and the rates used, and do not estimate. Our team can show you how the conversion works in your case.
Related filings
- Form 8938 (FATCA): filed with your income tax return. Its thresholds are different and depend on filing status and residence. Many people must file both forms.
- Form 8621 (PFIC): required for certain foreign mutual funds. See mutual funds and PFIC.
- Form 3520 and 3520-A: may apply to foreign trusts and some foreign retirement arrangements. See EPF and PPF.
Next steps
- List every Indian account and product you have held in each year, including closed ones.
- Record the highest balance of each account during each year.
- Check which forms apply using our accounts chart.
- If a year was missed, do not file on your own without reviewing options. Request a review.
General educational information. FBAR, Form 8938 and related rules depend on individual facts and change over time. Confirm current thresholds, due dates and forms on fincen.gov and irs.gov, and consult a qualified professional before filing.