FBAR Filing Step by Step: FinCEN Form 114 for Indian and Canadian Accounts

FBAR filing step by step starts with one fact: the Report of Foreign Bank and Financial Accounts, FinCEN Form 114, is not a tax form. It is a Bank Secrecy Act report filed electronically with the Treasury's Financial Crimes Enforcement Network, not with your tax return. A US person with a financial interest in, or signature authority over, foreign accounts must file if the combined value exceeded $10,000 at any time in the calendar year. For people with Indian NRE and NRO accounts, Canadian RRSPs and TFSAs, or a parent's account in Pune or Mississauga, that threshold is crossed very easily.

Who must file an FBAR?

A US person must file. That means a citizen, a resident under the tax residency tests in section 7701(b) (a green card holder or someone meeting the substantial presence test), and US entities such as corporations, partnerships, LLCs, trusts and estates. Tax treaty status does not change it: the IRS guide gives the example of a green card holder who elects to be a tax resident of the United Kingdom under a treaty, and who is still a US person for the FBAR.

You have a financial interest if you are the owner of record or holder of legal title, if someone holds the account as your agent or nominee, or if you own more than 50% of an entity that holds it. You have signature authority if you can control disposition of the assets by direct communication with the bank, even if you never use it. A US-resident child with power of attorney over a parent's account in Canada must report it. For joint accounts, each US person reports the entire balance.

Which Indian and Canadian accounts count?

FBAR filing step by step

1. List every foreign account where you have an interest or signature authority. Record the account name, number, bank name and address, account type and maximum value.
2. Find the maximum value in the account's currency. A reasonable approximation of the highest balance during the year is acceptable, and you may rely on periodic statements issued at least quarterly if they fairly reflect it.
3. Convert to US dollars using the Treasury Reporting Rates of Exchange for the last day of the calendar year, applied to each account's maximum.
4. Add the maxima. If the total is over $10,000 you must file; every account is then reported, even small ones.
5. Open the BSA E-Filing System. An individual can file without registering. A CPA, attorney or enrolled agent filing for a client registers and files as an institution.
6. Complete FinCEN Form 114 online: Part I (filer), Part II (accounts where you have a financial interest), Part III (owners of joint accounts), Part IV (accounts where you have only signature authority), and the signature section. For 25 or more accounts, tick the box, enter the number and keep the details.
7. Spouses: a spouse who owns only jointly held accounts can be covered by the other spouse's timely signed FBAR if both complete and sign FinCEN Form 114a. Keep the signed 114a; do not file it.
8. Save your confirmation and answer the foreign account question on Schedule B of Form 1040. File Form 8938 with the return if you pass its thresholds.

Documents and information you need

• Year-end and highest-balance statements for every account
• Bank name, address and account number
• Names and TINs of joint holders
• Treasury exchange rate for December 31
• Power of attorney or signature card where you only have authority
• Five years of records: the IRS says keep them for five years from the due date

Deadlines and penalties

The 2025 FBAR was due April 15, 2026, with an automatic extension to October 15, 2026. The 2026 FBAR is due April 15, 2027, extending automatically to October 15, 2027. Natural disasters can bring further relief, announced by FinCEN.

If you missed earlier years and the IRS has not contacted you, the IRS says to file the late FBARs as soon as possible and explain why. If the accounts are properly reported and the IRS finds reasonable cause, no penalty is imposed.

These figures are for penalties assessed on or after January 17, 2025 and are indexed each year. The Supreme Court held in 2023 (Bittner v. United States) that the non-willful penalty applies per late report, not per account. Penalties can exceed the account balance. See IRS foreign reporting penalties.

Country and Illinois notes

For a side-by-side view see the FBAR, T1135 and Schedule FA comparison and the reporting deadlines compared.

Worked example: Rohan and Meera, Naperville

Rohan, a green card holder, has an NRE account whose highest balance was $6,200, an NRO account at $3,100, an FD at $9,800 and a joint savings account with his father in Pune at $4,000 where he can sign. The total is $23,100. Even though no single account exceeds $10,000, he files an FBAR reporting all four, with the joint account listed in Part III. Meera is a joint holder on the NRE account, but she also owns a Toronto TFSA and RRSP worth $34,000 in her own name. Because not all of her accounts are joint, she cannot rely on Rohan's FBAR and files her own, reporting the joint NRE account and her Canadian accounts.

Mistakes to avoid

• Using the year-end balance instead of the highest balance during the year.
• Skipping small accounts when the total passes $10,000.
• Forgetting accounts where you only have signature authority.
• Assuming a treaty or a tax-exempt account removes the FBAR duty.
• Filing the FBAR with your tax return or after the October 15 extended date without explaining.
• Overlooking foreign accounts held through a business you control.

How we can help

Our firm, serving Aurora and the Fox Valley, files the FBAR electronically through FinCEN's BSA E-Filing System, builds your account inventory, converts balances and coordinates the FBAR with Form 8938 and your return. We work with your Canadian CPA or Indian CA so Schedule FA, T1135 and FinCEN 114 agree. See our foreign account and asset reporting page and the 2026 reminders.

Frequently asked questions

General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.