What counts as a foreign financial account?

Bank accounts, brokerage, certain pension arrangements, precious-metals accounts, insurance with cash value, cryptocurrency held on foreign exchanges, and accounts where you have signature authority — even if you're not the beneficial owner.

Do ISAs count toward the $10k threshold?

Cash ISAs yes. Stocks-and-shares ISAs generally yes — the underlying brokerage accounts are typically reportable. Help-to-Buy and Lifetime ISAs also count.

What happens if I miss the FBAR filing?

FBAR civil penalties are statutory maximums, and the dollar caps are adjusted for inflation. For non-wilful violations only, the Supreme Court's 2023 decision in Bittner means the penalty applies per annual FBAR report, not per account — up to $16,536 per report, and it can be $0 where there is reasonable cause. Bittner did not change wilful penalties: the maximum is the greater of $165,353 or 50% of the account balance at the time of the violation (the 50% rule is not inflation-adjusted). These dollar maximums are set in 31 CFR 1010.821 for penalties assessed on or after 17 January 2025; there was no 2026 inflation adjustment, so they were still current at our October 2026 review, but they can change for penalties assessed later. Catch-up through the Streamlined procedures typically resolves non-wilful cases without these penalties.

Does FBAR replace Form 8938?

No — they're separate filings with different rules, thresholds, and account definitions. You often need both. FBAR goes to FinCEN electronically; 8938 attaches to your 1040.

15 April with an automatic extension to 15 October. Filed electronically to FinCEN (not the IRS). No separate extension request is needed.

◉ Foreign Asset Reporting

FBAR — Foreign Bank Account Reporting (FinCEN 114)

Required if your foreign financial accounts exceeded $10,000 in aggregate at any point during the calendar year.

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Short answer

If the combined value of your non-US financial accounts — including UK current accounts, savings, ISAs and some pensions — exceeded $10,000 at any point in the calendar year, you must file an FBAR (FinCEN Form 114) electronically with FinCEN by 15 April, with an automatic extension to 15 October. It is separate from your tax return and carries its own penalties.

Overview

Why this filing matters

Required if your foreign financial accounts exceeded $10,000 in aggregate at any point during the calendar year.

Note — >$10k in foreign accounts — aggregate across the year.

◉ Who this is for

•US persons with UK bank accounts
•Signatories on foreign employer or trust accounts
•Clients with joint UK accounts

✓ What you get

✓FBAR preparation & e-filing to FinCEN
✓Account aggregation & maximum balance analysis
✓Guidance on signature authority reporting

At a glance

Key forms: FinCEN 114
Category: Foreign Asset Reporting
Turnaround: 2–3 weeks once documents are complete
Filed by: ACCA-qualified IRS Enrolled Agent

Our approach

Every account mapped before anything is filed.

FBAR, Form 8938 and Form 8621 overlap but are not the same: different thresholds, different account definitions, different homes (FinCEN vs your 1040), and different penalties. A UK current account, an ISA, a workplace pension and a stocks-and-shares account can each land on a different form — or on two.

We start by mapping every foreign account and asset you hold or have signature authority over, then slot each one onto the forms that actually apply, so nothing is double-counted and nothing is missed. Where an ISA or fund turns out to be a PFIC, we catch it before it becomes a Form 8621 problem.

Full account and asset inventory, with signature-authority holdings included
Each asset mapped to FBAR, 8938 and/or 8621 — no double-counting, no gaps
PFIC exposure inside ISAs and funds identified before it compounds

Adviser reviewing foreign financial account records for FBAR and FATCA reporting

Our process

How we handle your filing

Four steps from first email to filed return. Fixed fee confirmed in writing before any work begins.

Intake

Send us your situation by email or the enquiry form. We come back with the questions we need answered — every source of income for the year, filing history, accounts and entities — and a tailored document list.

Review

We analyse your position, flag any cross-border risks, and confirm the scope and fixed fee in writing before any work starts.

Prepare

Draft returns and schedules are prepared with plain-English commentary on key positions for your review.

File

You sign electronically; we e-file with the IRS / FinCEN and send you the acceptance confirmations for your records.

Pricing

Fixed fees — no surprises

FBAR is £150 + VAT when bundled with a tax return, or £250 + VAT standalone. Multi-year catch-up filings and Streamlined FBAR packages are priced per case.

Prices are indicative starting points and exclude UK VAT, which applies to UK-resident clients only. We quote in writing once we have confirmed every source of income and your filing history for the years involved.

Request fee quote See full pricing →

FAQs

Common questions

Sources

Rules, thresholds and penalties are as published by the IRS and FinCEN at the time of our last review (2026-09-08); always check the current instructions for the year you are filing.

Related services

Others in Foreign Asset Reporting

FATCA reporting (Form 8938)

Report specified foreign financial assets on Form 8938 when thresholds are met — separate from, and in addition to, FBAR.

Learn more →

PFIC / ISA reporting (Form 8621)

UK ISAs, unit trusts, and OEICs are typically PFICs for US tax purposes — triggering punitive taxation unless elected properly.