FBAR: the report the U.S. Treasury
requires you to file
If your LLC or you as owner have bank accounts outside the U.S., the federal government needs to know which accounts, where they are and who controls them. Not optional. Not the IRS. It's FinCEN.
What is the FBAR and why does it exist?
The FBAR (Foreign Bank Account Report) is a form FinCEN requires to know every financial account a U.S. person or entity owns or controls outside the U.S.
It's not a tax. Nothing is paid when filing. But not filing
triggers automatic penalties starting at $13,640 per account,
even if the failure was unintentional.
It's an informational requirement, not a tax one. But the consequences are real.
When it applies
If you or your LLC have bank accounts outside the U.S. whose aggregate balance exceeds $10,000 at any point in the year.
What is reported
Account number, bank name, country, account type and the year's maximum balance.
Where it's filed
Electronically through FinCEN's BSA E-Filing system. Not with the IRS.
Who is affected
Any U.S. person (including LLCs) with financial authority over foreign accounts above the threshold.
What happens if you don't file
The FBAR has its own penalty regime, separate from the IRS. And the penalties are not small.
Non-willful failure
Penalty up to $13,640 per account for each unreported year. It stacks.
Willful failure
Penalty up to $136,399 per account or 50% of the balance, whichever is greater. Possible criminal liability.
Automatic deadline
April 15 with automatic extension to October 15. You don't need to request the extension.
6-year lookback
FinCEN can audit the last 6 years of reports. If you didn't file, the window stays open.
How it works
You give us your account info; we handle the rest.
You send us your account information
Bank name, account number, account type and the tax year's maximum balance. If you're a Tax Filing client, we already have it.
We prepare FinCEN Form 114
We complete the report with your data and verify consistency and format.
Electronic submission to FinCEN
We file it directly in the BSA E-Filing system. You receive confirmation and a copy of the submitted report.
Clear pricing, no surprises
Included with your annual Tax Filing. No extra cost.
- FBAR included in the filing
- Joint submission 1120 + 5472 + FBAR
- Verifiable copy of the report
- No additional paperwork
For those who already filed their tax return but need the FBAR separately.
- FinCEN 114 form
- Electronic submission via BSA E-Filing
- Confirmation + copy of the report
- Support during the process
If you have the Manager Plan ($3,600/year), FBAR is included alongside Tax Filing and the rest of annual compliance — no separate purchase needed.
FBAR questions
If the aggregate balance across all accounts never exceeded $10,000 at any point in the year, you're not required to file the FBAR. When in doubt, verify — don't assume.
No. The FBAR is filed with FinCEN. FATCA (Form 8938) is filed with the IRS. These are two separate obligations with different thresholds and forms. For disregarded LLCs, FBAR usually applies.
Technically yes, through the BSA E-Filing portal. But the process requires knowing exactly which accounts to file, how to calculate the maximum balance and in what format. An error can trigger penalties.
There are procedures to regularize prior years. Contact us to assess your specific situation. Voluntary regularization is better than waiting for FinCEN to detect it.
This service is limited to preparing and electronically filing FinCEN Form 114 (FBAR) in the BSA E-Filing system of the U.S. Department of the Treasury.
Devil Club does not provide binding legal, tax or accounting advice. Penalty amounts shown are illustrative and may vary based on current legislation. Each case is evaluated individually.