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FBAR Green Card Holders: What Permanent Residents Must Know

Matt Cohen, CPA ·

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

FBAR Green Card Holders: What Permanent Residents Must Know

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

FBAR Green Card Holders: What Permanent Residents Must Know

If you hold a green card, the United States government treats you the same as a citizen for taxes and reporting. You must file an FBAR to report foreign bank and financial accounts that exceed $10,000 in aggregate value at any point during the calendar year. The FBAR — formally referred to as the Report of Foreign Bank and Financial Accounts — is a FinCEN form required of every US person, including all green card holders.

Many new immigrants are surprised that FBAR filing is separate from their tax returns. Do green card holders pay taxes on foreign income? Yes. The FBAR is an additional form on top of those taxes. Card holders who fail to report foreign bank and financial accounts face penalties under federal law. This guide covers who must file, which accounts count, the filing procedures, and what to do if you are behind on your taxes and reporting.

Are Green Card Holders Required to File an FBAR?

Yes. Green card holders are "United States persons" under 31 CFR 1010.350(b). That regulation lists citizens, residents, and lawful permanent resident aliens as US persons for taxes and reporting. If you hold a green card, you must file an FBAR whenever your foreign financial accounts exceed $10,000 in aggregate value during the calendar year.

What Makes a Green Card Holder a US Person?

A green card holder is a lawful permanent resident under 8 USC 1101(a)(20). The Internal Revenue Service (IRS) and FinCEN both treat lawful permanent residents as US persons for tax purposes. This applies regardless of how long you have held the card or which foreign country you came from. Tax treaty elections do not remove your obligation to report foreign bank accounts on the FBAR. A treaty may reduce your income taxes, but it does not eliminate FinCEN reporting duties. For more on who qualifies, see who is a US person for FBAR filing.

When Does the Filing Obligation Start?

Your FBAR filing obligation starts the calendar year you receive your green card, per IRS FBAR guidance. The key date is the date on your I-551 card or passport stamp. Even if you got your green card on December 15, you must report foreign bank and financial accounts for the full calendar year. FinCEN does not prorate the filing. New immigrants often assume their obligation starts the following year, but that is incorrect.

Example: Priya's First-Year Filing

Priya got her green card on September 8. She has a bank account in India worth about $18,000. Even though she held the card for four months, the FBAR covers the full year. Her account exceeded $10,000, so she must file an FBAR. The due date is April 15 of the following year per 31 CFR 1010.306(c). FinCEN grants an automatic extension to October 15.

Which Foreign Financial Accounts Must You Report?

You must report every foreign financial account in which you have a financial interest or signature authority. Under 31 CFR 1010.350(c), any account at an institution outside the United States is a foreign financial account. The type of account, how long you have held it, and whether it earns income do not change the rules.

Home-Country Accounts

All accounts in your home country count. This includes accounts you opened before you became a tax resident of the United States. You must report checking accounts, savings accounts, and fixed deposits. Many immigrants who reside in the US keep foreign accounts to support family, hold money, or receive income from abroad. Every one of those accounts is reportable once you hold a green card.

Retirement and Pension Accounts

Foreign retirement accounts generally qualify as foreign financial accounts under FinCEN instructions. Tax-free status in a foreign country does not exempt an account from FBAR reporting. Taxpayers from India must report PPF and NPS accounts. Those from the United Kingdom must report SIPPs and ISAs. Canadian immigrants must report RRSP and TFSA accounts. Australian residents must report superannuation (referred to as "super"). See FBAR India NRE/NRO accounts, FBAR UK bank accounts, and FBAR Canada RRSP/TFSA.

Account Types You Must Report

Account Type Reportable? Notes
Foreign bank accounts (checking, savings, CDs) Yes All deposit accounts at a foreign bank
Foreign brokerage accounts Yes Stocks, bonds, mutual funds
Foreign retirement accounts (PPF, RRSP, SIPP) Yes Tax-free status does not exempt
Foreign insurance with cash value Yes Whole life, endowment, annuity
Accounts with signature authority only Yes Even without ownership
US domestic accounts No Not reportable

Common Reportable Accounts by Country

Country Reportable Accounts Notes
India NRE, NRO, savings, FDs, PPF, NPS All types subject to FBAR
United Kingdom Current, savings, ISAs, SIPPs UK tax benefits do not apply
Canada Chequing, savings, TFSA, RRSP Tax-sheltered accounts are reportable
Australia Savings, term deposits, super Generally qualifies
Israel Accounts, pensions See Israel guide

How Do You File an FBAR?

You file the FBAR through the BSA E-Filing site at FinCEN. The form is FinCEN Form 114. You do not file the FBAR with your tax returns. It goes to FinCEN, not the IRS. Filing takes most taxpayers 15 to 30 minutes.

Information You Need to File the FBAR

Gather these details before you file an FBAR:

  1. Personal information: Full name, SSN or ITIN, date of birth, address
  2. Account details: Name of the foreign bank, account number, type
  3. Maximum value for the calendar year in USD using Treasury exchange rates
  4. Country where each institution is located

For instructions on converting money, see how to calculate maximum account value for FBAR.

Filing on the BSA E-Filing Site

You can file the 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 are a FinCEN-registered institution (TCC: PBSA8180) that files directly to FinCEN. Upload your statements, and we handle conversion, form preparation, and filing.

What Is the FBAR 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. No form is needed for the extension. For details, see FBAR filing deadline 2026.

Do You Report Joint Accounts With a Non-US Spouse?

Yes. If you have a financial interest in or signature authority over a joint account, you report the full value. Under the FinCEN Form 114 instructions, each US person reports 100 percent of the total value. You do not split the money with your spouse. This applies even if your spouse is a foreign national with no filing obligation. See FBAR joint account reporting rules.

Example: Carlos and Maria

Carlos is a green card holder. Maria, his wife, is a Mexican citizen with no US status. They share a joint account at Banorte with a peak balance of $20,000. Carlos must file the FBAR and report the full $20,000. Maria has no obligation. If she later gets a green card, she must also file FBARs.

How Does the FBAR Compare to Form 8938?

Taxpayers who are tax residents file multiple forms for their foreign assets and income. The FBAR and Form 8938 — referred to as the FATCA form under 26 USC 6038D — both require you to report foreign financial accounts. The FBAR threshold is $10,000 in aggregate value. Form 8938 starts at $50,000 for taxpayers who reside in the US. You file the FBAR to FinCEN and Form 8938 with your tax returns to the IRS. See FBAR vs. FATCA Form 8938.

FBAR Obligations by Type of US Person

Obligation Green Card Holders Citizens Residents (Substantial Presence)
Must file FBAR? Yes Yes Yes
Threshold $10,000 aggregate $10,000 aggregate $10,000 aggregate
Home-country accounts? Yes Yes Yes
Deadline April 15 (auto-ext Oct 15) April 15 (auto-ext Oct 15) April 15 (auto-ext Oct 15)
Taxes on worldwide income? Yes Yes Yes
Treaty FBAR exemption? No No No

The government applies the same FBAR rules and taxes obligations to all categories.

What Are the FBAR Penalties?

Penalties for failing to file the FBAR are severe. FinCEN applies them to all US persons equally. The government does not reduce penalties based on immigration status.

Non-willful penalties: Up to $16,117 per violation per year under 31 USC 5321(a)(5)(B)(i) (2025 inflation-adjusted; base $12,909 per 31 USC 5321). Each unreported account per year is one violation. Three accounts over two years could mean six violations and up to $96,702 in penalties per 31 USC 5321.

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

Criminal penalties: Fines up to $250,000 and 5 years imprisonment under 31 USC 5322. The government generally reserves criminal prosecution for deliberate concealment of money or taxes. See FBAR penalties guide and willful vs. non-willful penalties.

What If You Missed Filing?

Green card holders who missed past FBARs should come into compliance before the IRS contacts them. The IRS offers resources and compliance programs to assist taxpayers who did not know about the filing rules.

IRS Streamlined Filing Compliance Procedures

The IRS Streamlined Filing Compliance Procedures let immigrants and other taxpayers catch up with reduced penalties per IRS procedures:

  1. File the last 3 years of delinquent tax returns (if you owe taxes)
  2. File the last 6 years of delinquent FBARs
  3. Pay a 5% offshore penalty on the highest aggregate value (Domestic Streamlined per IRS guidance). Foreign nationals who qualify for Foreign Streamlined pay no penalty per IRS rules
  4. Certify that your failure was non-willful

A green card holder with $150,000 in unreported accounts pays $7,500 per IRS procedures. That is far less than $96,702 in non-willful penalties under 31 USC 5321. See FBAR streamlined filing guide.

Delinquent FBAR Submission Procedures

If your accounts earned no income and you reported all taxes correctly, check the Delinquent FBAR Submission Procedures. The IRS may waive penalties when all income taxes were paid. See delinquent FBAR filing guide.

When to Get Professional Help

Seek a qualified tax professional if:

  • You have unreported foreign income on your tax returns
  • Your accounts exceed $500,000 in total value
  • You hold foreign trusts, foreign corporations, or other authority over business accounts
  • You received IRS correspondence about foreign accounts or taxes

For standard filing, FBAR Direct handles filings starting at $59 on our site. We prepare your FinCEN Form 114 and file to FinCEN on your behalf.

Key Takeaways

  • Green card holders must file an FBAR under the same rules as citizens
  • Filing begins the calendar year you receive your green card
  • Report all foreign bank accounts, retirement accounts, and other foreign financial accounts
  • Home-country accounts held before you became a tax resident still count
  • Report joint accounts at full value — do not split with a non-US spouse
  • The FBAR is separate from your tax returns
  • Non-willful penalties reach $16,117 per account per year under 31 USC 5321

Frequently Asked Questions

Do green card holders need to file an FBAR?

Yes. Green card holders are US persons under 31 CFR 1010.350(b). You must file an FBAR if your foreign financial accounts exceed $10,000 in aggregate at any point during the calendar year. The rules match those for citizens.

When does the filing obligation start for new immigrants?

Your obligation begins the calendar year you receive your green card per IRS guidance. Even if you got your card in December, you must determine whether your foreign accounts exceeded $10,000 that year. FinCEN does not prorate based on months.

Do you report home-country accounts on the FBAR?

Yes. Under 31 CFR 1010.350(c), any account at a foreign bank is a foreign financial account. This includes accounts opened before you became a US person. The key factor for determining reportability is the location of the institution.

What are the penalties for not filing?

Non-willful penalties reach $16,117 per account per year under 31 USC 5321(a)(5). Willful penalties reach $100,000 or 50 percent of the balance. Criminal penalties include fines up to $250,000 under 31 USC 5322. The IRS does not reduce penalties based on immigration status.

Can you file the FBAR jointly with a spouse?

Yes, if both spouses are US persons and all accounts are jointly owned. Both must sign the form. If either spouse holds an account alone, that person files a separate FBAR. The non-filing spouse must complete FinCEN Form 114a and keep it for five years. See FBAR joint account reporting guide.

Does the FBAR apply after you surrender your green card?

Your filing obligation ends the year you formally give up your permanent resident status. You must file for every year you held the card per IRS rules. Green card holders who reside abroad should also review the FBAR vs. Form 8938 differences when determining their full obligations.

Let FBAR Direct Handle Your Filing

Filing the FBAR means gathering foreign bank statements, converting money to USD using Treasury rates, and completing FinCEN Form 114. Many immigrants who reside in the US find the process confusing because the FBAR is separate from their income taxes and tax returns.

Let FBAR Direct prepare your filing — you review and approve before we submit to FinCEN on your behalf. Upload your 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 March 04, 2026.

The information in this article is current as of March 4, 2026. 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.

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