FBAR Direct prepares and files your FBAR (FinCEN Form 114) on your behalf. You must review all information for accuracy before we submit to FinCEN. This article is for informational purposes only. It does not constitute tax, legal, or financial advice.

FBAR Brazil Bank Accounts: Reporting Previdencia, FGTS, and Brazilian Assets

If you are a US person with bank accounts in Brazil, you need to file an FBAR when the aggregate value of your foreign financial accounts exceeds $10,000 at any point during the calendar year. The FBAR — formally the Report of Foreign Bank and Financial Accounts — is an annual filing that the Financial Crimes Enforcement Network (FinCEN) requires. Brazil creates unique reporting challenges. There is no comprehensive US-Brazil tax treaty, and Brazilian financial products like previdencia privada and FGTS don't have direct US equivalents. This guide covers which Brazilian accounts you must report, how to convert reais to dollars, and what happens if you don't file your FBAR.

Who Must File an FBAR for Brazilian Bank Accounts?

Every US person with a financial interest in or signature authority over foreign financial accounts that exceed $10,000 in aggregate value must file an FBAR. Under 31 CFR 1010.350(b), US persons include citizens, residents, and anyone meeting the substantial presence test. Therefore, Brazilian-Americans, green card holders, and dual citizens living in either country must report their Brazilian accounts to FinCEN.

Specifically, you must file an FBAR if you hold accounts at any Brazilian financial institution. This includes Banco do Brasil, Itau Unibanco, Bradesco, Santander Brasil, and Nubank. The type of foreign bank account does not matter — for example, checking accounts (conta corrente), savings accounts (poupanca), investment accounts, and retirement accounts all count as foreign accounts for FBAR purposes. Military banking personnel stationed abroad who maintain Brazilian accounts must also report them.

The $10,000 threshold applies to the aggregate value of all your foreign accounts combined — not each account on its own. For instance, if you have R$15,000 at Itau and R$25,000 at Bradesco, you add both balances together. When the combined USD equivalent exceeds $10,000 at any point during the year, you must file your FBAR.

Which FBAR Brazil Bank Accounts Must You Report?

You must report every foreign account in which you have a financial interest in or signature authority over. Brazilian accounts and financial products fall into several categories, and nearly all of them require reporting on the FBAR.

Bank and Financial Accounts

All deposit accounts at Brazilian banks are reportable. This includes conta corrente (checking), poupanca (savings), CDB (Certificado de Deposito Bancario), and Tesouro Direto (government bonds held through a brokerage). Accounts at digital banks like Nubank, Inter, and C6 Bank count the same as accounts at traditional banks.

Previdencia Privada (PGBL and VGBL)

Previdencia privada plans — both PGBL (Plano Gerador de Beneficio Livre) and VGBL (Vida Gerador de Beneficio Livre) — qualify as foreign financial accounts under FinCEN guidance. These plans function like retirement accounts and hold invested assets on your behalf at a Brazilian financial institution. However, tax-advantaged status in Brazil does not exempt these accounts from FBAR reporting. For more on foreign retirement accounts, see FBAR foreign pension and retirement accounts.

FGTS (Fundo de Garantia)

The FGTS (Fundo de Garantia do Tempo de Servico) is an employer-funded severance account. Brazilian employers maintain one for each employee, and your employer deposits 8% of your salary into a Caixa Economica Federal account each month. You have a financial interest in the account, and the funds sit at a foreign bank. Consequently, the FGTS is reportable on your FBAR. Even if you cannot freely withdraw from the account, FinCEN looks at financial interest — not whether you have direct access to the funds.

Mutual Funds and Brokerage Accounts

Brazilian investment funds (fundos de investimento), stocks held at B3 (the Brazilian stock exchange), and brokerage accounts are all foreign financial accounts. Report the maximum value of each account during the calendar year. If you hold mutual funds or ETFs through a Brazilian broker, those accounts are reportable too.

Brazilian Accounts Summary

Account Type	Reportable?	Notes
Conta corrente (checking)	Yes	All Brazilian bank accounts
Poupanca (savings)	Yes	Including digital banks
CDB, LCI, LCA	Yes	Fixed-income investments
Tesouro Direto	Yes	Government bonds via broker
Previdencia privada (PGBL/VGBL)	Yes	Retirement accounts at foreign institution
FGTS	Yes	Employer-funded, Caixa Economica
Fundos de investimento	Yes	Mutual funds and investment funds
Brokerage (B3 stocks)	Yes	Securities accounts
US-based accounts	No	Domestic accounts are not reportable

How to Convert Brazilian Real to US Dollars for FBAR

To convert Brazilian real to US dollars for your FBAR, use the Treasury Department's end-of-year exchange rate for the calendar year you are reporting. The Treasury publishes official rates at fiscal.treasury.gov. Report the maximum value — the highest balance at any point during the year, not the year-end balance. Convert using the December 31 rate.

For example, say your highest balance was R$60,000 and the Treasury rate was about 5.10 BRL per USD. You would report $11,765. You don't need to track daily rates. See how to calculate maximum account value for FBAR for a step-by-step guide and FBAR exchange rates for more details.

Worked Example: Filing an FBAR for Brazilian Bank Accounts

Here is how a real FBAR filing works for someone with multiple Brazilian accounts. Lucas is a US citizen living in Sao Paulo with five accounts across four banks. He adds up the maximum values, converts BRL to USD, and must file FBAR because the total exceeds $10,000:

Account	Institution	Maximum Balance (BRL)	USD Value (at 5.10 rate)
Conta corrente	Banco do Brasil	R$12,000	$2,353
Poupanca	Nubank	R$45,000	$8,824
PGBL previdencia	Bradesco	R$180,000	$35,294
FGTS	Caixa Economica	R$28,000	$5,490
CDB	Itau Unibanco	R$35,000	$6,863

Aggregate value: $58,824. Lucas reports all five accounts the FBAR requires on FinCEN Form 114 — listing the account number, bank name, maximum value in USD, and country (Brazil) for each. He also files his US tax return to report worldwide income, including interest from his poupanca and CDB.

Brazil-US Tax Treaty and FATCA IGA

No Comprehensive Tax Treaty

The United States and Brazil do not have a comprehensive income tax treaty. Unlike the United Kingdom and Canada, Brazil has only a limited agreement focused on information exchange — not double taxation relief. As a result, you cannot claim treaty-based tax relief to cut US taxes on Brazilian income. Instead, use foreign tax credits on your tax return.

Additionally, the lack of a treaty does not change your FBAR filing obligation. The FBAR is a FinCEN requirement under the Bank Secrecy Act (BSA), not a tax form. No treaty can exempt you from filing.

FATCA IGA Model 1

Brazil signed a FATCA Intergovernmental Agreement (IGA) Model 1 with the United States in 2014. Brazilian financial institutions — Banco do Brasil, Itau, Bradesco, Santander Brasil — report US account holder data to the Receita Federal (Brazil's tax authority). The Receita Federal shares this data with the IRS.

Therefore, the IRS already knows about your Brazilian accounts. The banks identify US persons and report account balances, interest income, and other data under FATCA. If you don't file your FBAR and the IRS gets FATCA data showing foreign accounts, you face penalties and enforcement action.

FBAR vs. Form 8938 for Brazilian Assets

The FBAR and Form 8938 (FATCA form) are separate filings with different thresholds and different agencies. US persons with Brazilian assets often need to file both forms. The FBAR goes to FinCEN while Form 8938 goes to the IRS with your tax return. Each form has its own dollar threshold and covers a different set of assets.

Feature	FBAR (FinCEN Form 114)	Form 8938
Filed with	FinCEN (BSA filing system)	IRS (with your tax return)
Threshold (US residents)	$10,000 aggregate	$50,000 (single) / $100,000 (married)
Threshold (living abroad)	$10,000 aggregate	$200,000 (single) / $400,000 (married)
Assets covered	Foreign financial accounts	Accounts + foreign assets, securities, interests
Due date	April 15 (automatic extension to October 15)	With your tax return
Penalties	Up to $16,117 non-willful per violation	Up to $10,000 per failure

You can file the FBAR form through the BSA filing system at FinCEN. Form 8938 is filed with your tax returns to the IRS. For a detailed comparison, see FBAR vs. FATCA Form 8938 differences.

What Are the FBAR Penalties?

FBAR penalties for failing to report foreign accounts and financial interests are severe. FinCEN applies them to all US persons — citizens, residents, and dual nationals. If you hold Brazilian bank accounts and don't file, here is what you risk.

Non-willful penalties: Up to $16,117 per violation per year under 31 USC 5321(a)(5)(B)(i) (2025 inflation-adjusted). Each unreported account per year counts as one violation. Lucas's five accounts over two years could mean ten violations — up to $161,170.

Willful penalties: The greater of $100,000 or 50% of the account balance per year under 31 USC 5321(a)(5)(C).

Criminal penalties: Fines up to $250,000 and 5 years in prison under 31 USC 5322.

In other words, you cannot skip filing your FBAR because Brazil shares data with the IRS through FATCA. The FBAR is a separate legal requirement. You can face penalties even if all your taxes were filed correctly. See FBAR penalties guide.

What If You Missed Filing Your FBAR?

If you missed filing your FBAR and have unfiled years, don't panic. Many Brazilian-Americans discover the requirement years after becoming US persons. Fortunately, the IRS offers programs to help you file delinquent FBARs and come into compliance before enforcement action.

Streamlined Filing Compliance Procedures

The IRS Streamlined Filing Compliance Procedures let you catch up with reduced penalties:

File the last 3 years of amended or delinquent tax returns
File the last 6 years of delinquent FBARs
Pay a 5% offshore penalty on the highest aggregate value (Domestic Streamlined). Those living abroad who qualify for Foreign Streamlined pay no penalty
Certify that your failure was non-willful

Many Brazilian-Americans abroad qualify for Foreign Streamlined, which carries no penalty at all. See FBAR streamlined filing guide.

Delinquent FBAR Submission Procedures

If you reported all foreign income on your tax returns but missed filing the FBAR, the Delinquent FBAR Submission Procedures may apply. The IRS may waive penalties if you reported all income correctly. These procedures work best when you filed accurate tax returns but didn't know about the FBAR.

How to File Your FBAR for Brazilian Bank Accounts

The FBAR form is FinCEN Form 114. You file it online through the BSA E-Filing site. Don't file it with your tax return — the FBAR goes to FinCEN, not the IRS.

Information You Need

Gather this information for each Brazilian account before filing:

Institution name (e.g., Banco do Brasil, Itau Unibanco, Bradesco)
Account number as shown on your Brazilian bank statement
Account type (checking, savings, investment, retirement)
Maximum value during the year in USD using Treasury exchange rates
Country: Brazil

Filing Deadline

The FBAR due date is April 15 of the following year per 31 CFR 1010.306(c). FinCEN grants an automatic extension to October 15. You don't need to request it — no form is required.

You can file FBAR yourself on the BSA E-Filing site at bsaefiling.fincen.gov. Or FBAR Direct can prepare your FinCEN Form 114 on your behalf. We file directly to FinCEN as a registered institution (TCC: PBSA8180).

If you are a first-time filer, the process takes about 15 to 30 minutes when you have your statements ready.

Frequently Asked Questions

Below are the most common questions about FBAR you need to know when reporting Brazilian accounts. The answers cover thresholds, account types, currency conversion, and penalties for US persons with foreign accounts in Brazil.

Do I need to file an FBAR for my Brazilian bank accounts?

Yes. You must file an FBAR if you are a US person and the aggregate value of your foreign financial accounts exceeds $10,000 at any point during the calendar year. This includes all Brazilian accounts. The FBAR is an annual filing required under 31 CFR 1010.350. It applies to US citizens, green card holders, and residents meeting the substantial presence test.

Is previdencia privada reportable on the FBAR?

Yes. Both PGBL and VGBL previdencia privada accounts are generally reportable as foreign financial accounts. These accounts hold assets at a Brazilian financial institution on your behalf. Tax-deferred or tax-free treatment under Brazilian law does not exempt them from FBAR reporting.

Do I report FGTS on the FBAR?

Yes. The FGTS is an account held at Caixa Economica Federal. You have a financial interest in it. Even though your employer funds it and withdrawals are restricted, FinCEN looks at financial interest — not access. Report the maximum value of your FGTS account during the year.

How do I convert Brazilian real to USD for FBAR?

Use the Treasury Department's end-of-year exchange rate from fiscal.treasury.gov. Find the highest balance for each account during the year. Convert using the December 31 rate. You don't need to track daily rates.

Is there a US-Brazil tax treaty that affects FBAR filing?

No. The United States and Brazil do not have a comprehensive income tax treaty. A limited information exchange agreement exists, but it does not reduce FBAR reporting obligations. The FBAR is a BSA requirement administered by FinCEN. No tax treaty can override it.

Do Brazilian banks report my accounts to the IRS?

Yes. Under the FATCA IGA Model 1 agreement signed in 2014, Brazilian financial institutions report US account holder data to the Receita Federal. The Receita Federal shares it with the IRS. Banks like Banco do Brasil, Itau Unibanco, Bradesco, and Santander Brasil actively identify US person accounts.

What happens if I don't file my FBAR for Brazilian accounts?

You face penalties under 31 USC 5321. Non-willful penalties reach $16,117 per violation. Willful penalties reach $100,000 or 50% of the account balance. If you missed filing, the IRS Streamlined Procedures offer a path to compliance with reduced or no penalties. See FBAR penalties guide.

Can I file my FBAR and tax return together?

No. The FBAR goes to FinCEN through the BSA E-Filing system. Your tax return goes to the IRS. These are separate filings with separate due dates and separate penalties. The FBAR due date is April 15 with an automatic extension to October 15. Don't confuse the two.

Let FBAR Direct Handle Your Filing

Filing the FBAR for Brazilian accounts means gathering statements from multiple banks. You need to convert reais to dollars using Treasury rates and complete FinCEN Form 114 for each account. Between previdencia privada, FGTS, poupanca, and regular bank accounts, many filers have five or more accounts to report.

Let FBAR Direct prepare your filing — you review and approve before we submit to FinCEN on your behalf. Upload your Brazilian bank statements and we handle conversion, form preparation, and filing. See how it works.

Tax regulations change frequently. Always verify current requirements at IRS.gov or FinCEN.gov. For advice specific to your situation, consult a qualified tax professional. This article is current as of April 9, 2026.