FBAR Taiwan Bank Accounts: Reporting Requirements for US Persons
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 Direct prepares and files your FBAR (FinCEN Form 114) on your behalf. You must review all details for accuracy before we submit to FinCEN. This article is for information only and is not tax, legal, or financial advice.
FBAR Taiwan Bank Accounts: Reporting Requirements for US Persons
If you hold bank accounts in Taiwan, you must file an FBAR when the total value of all your foreign accounts tops $10,000 at any point during the year. You file the FBAR — the Report of Foreign Bank and Financial Accounts — on FinCEN Form 114. Taiwan's banking system has account types that catch Americans off guard. These range from postal savings at Taiwan Post (郵局) to the Labor Pension Fund (勞工退休金). No US-Taiwan tax treaty exists, so no special exemptions apply. This guide covers which accounts you need to report, how to convert TWD to USD, and the penalties for not filing.
Who Must File an FBAR for Taiwan Accounts?
You must file an FBAR if you hold or have signature authority over foreign accounts in Taiwan. This applies when the total value of all foreign accounts tops $10,000 at any point during the year. Under 31 CFR 1010.350(b), a US person includes:
- US citizens living in Taiwan or elsewhere
- Green card holders (lawful permanent residents)
- Individuals who meet the substantial presence test
- Certain entities such as a corporation, partnership, or trust organized in the United States
For example, Americans in Taiwan keep accounts at Bank of Taiwan, CTBC Bank, Cathay United Bank, E.SUN Bank, Mega Bank, or Fubon. Each of these accounts goes on the FBAR if you meet the $10,000 mark. The type of account — checking, savings, time deposit, or brokerage — does not change the rule.
If you are a first-time filer, see our first-time filer guide for step-by-step instructions.
Which FBAR Taiwan Bank Accounts Must You Report?
Under 31 CFR 1010.350(c), any account held at the foreign bank, brokerage, or other financial institution outside the United States is a foreign account. You must report Taiwan accounts such as bank accounts, brokerage accounts, postal savings, pension funds, and cash value insurance policies. These fall into several groups.
Common Taiwanese Account Types
| Account Type | Reportable? | Notes |
|---|---|---|
| Bank accounts (checking, savings, CDs) | Yes | Bank of Taiwan, CTBC, E.SUN, Cathay United, Fubon, Mega |
| Taiwan Post savings (郵局儲金) | Yes | Postal savings accounts are foreign bank accounts |
| Brokerage accounts | Yes | Stocks, bonds, and mutual funds held at Taiwan brokerages |
| Labor Pension Fund — New System (新制) | Generally Yes | Government-managed defined contribution pension |
| Labor Pension Fund — Old System (舊制) | Generally Yes | Employer-funded defined benefit pension |
| Labor Insurance (勞工保險) | Depends | May qualify if it has a cash value component |
| National Health Insurance (健保) | No | Not a financial account — this is a government health program |
| Foreign currency accounts (USD, JPY) | Yes | Multi-currency accounts at Taiwanese banks are reportable |
| Insurance policies with cash value | Yes | Whole life or endowment policies from Taiwanese insurers |
Report each account in which you have a financial interest or signature authority. You must report even if the account earned no income during the year. For more on foreign pension reporting, see FBAR foreign pension and retirement accounts.
Taiwan's Labor Pension Fund
The Taiwan Labor Pension Fund deserves special attention. Under the new system (新制), both the employer and the worker contribute to a personal pension account. The Bureau of Labor Funds manages this account. FinCEN says foreign retirement accounts count as foreign financial accounts you must report on the FBAR. The account has a clear value — the Bureau of Labor Funds sends an annual statement with your balance. You can also check your balance on the Bureau of Labor Insurance website or at any post office.
The old system (舊制) works as a defined benefit plan that the employer funds. Whether you must report this account depends on your ownership interest in a separate fund. If the employer holds the funds in a separate account for you, you must report it. However, if the benefit is an unfunded promise from the employer, you do not. Contact a tax attorney if you are unsure which category your pension falls into.
How to Convert TWD to USD for the FBAR
To convert TWD to USD for the FBAR, use the official Treasury Department exchange rates. You must report the maximum value of each Taiwan account during the calendar year in US dollars. The Treasury publishes rates for the New Taiwan Dollar (TWD/NTD) at fiscal.treasury.gov. Use the rate for the last day of the year the account hit its highest value.
Worked Example: Chen's Taiwan Accounts
Chen is an American citizen working in Taipei. She has the following accounts:
| Account | Institution | Peak Balance (TWD) | Treasury Rate | USD Value |
|---|---|---|---|---|
| Savings account | E.SUN Bank | NT$450,000 | 31.5 TWD/USD | $14,286 |
| Time deposit | Bank of Taiwan | NT$300,000 | 31.5 TWD/USD | $9,524 |
| Brokerage account | Cathay Securities | NT$180,000 | 31.5 TWD/USD | $5,714 |
| Labor Pension Fund (新制) | Bureau of Labor Funds | NT$220,000 | 31.5 TWD/USD | $6,984 |
Total aggregate value: $36,508
Chen must file an FBAR because her total value exceeds $10,000. She reports all four accounts on FinCEN Form 114. She lists each account with its own peak value. For more details, see FBAR exchange rates and Treasury Department rates and how to calculate maximum account value for FBAR.
Taiwan and FATCA: The AIT-TECRO IGA Framework
Taiwan takes part in the Foreign Account Tax Compliance Act (FATCA) through a unique setup. The United States does not recognize Taiwan as a sovereign state. Taiwan cannot sign a standard intergovernmental agreement (IGA). Instead, the American Institute in Taiwan (AIT) and the Taipei Economic and Cultural Representative Office (TECRO) signed a FATCA Model 2 IGA in 2016.
Under this Model 2 deal, Taiwanese banks report account data for American holders directly to the IRS. The IRS will already have details about your accounts in Taiwan. Banks such as CTBC, Fubon, Mega, and Cathay United all follow FATCA rules. If you hold accounts in Taiwan and skip the FBAR, the IRS may already know about those accounts through FATCA data sharing.
In addition to the FBAR, you must file Form 8938 if you meet higher thresholds under 26 USC 6038D. The Form 8938 threshold starts at $50,000 for those in the United States and $200,000 for those living overseas. See FBAR vs. FATCA Form 8938 differences.
No US-Taiwan Tax Treaty: What It Means for FBAR Filers
There is no income tax treaty between the United States and Taiwan. US persons with Taiwanese accounts cannot rely on treaty benefits for lower withholding or special exemptions. This creates several key issues for FBAR filers:
- No treaty-based FBAR exemption: Tax treaties never exempt US persons from FBAR filing. No treaty also means no lower withholding rates
- Double taxation risk: Income from Taiwanese accounts may face both Taiwan and US federal income tax. The foreign tax credit under 26 USC 901 can offset some of this
- No information exchange treaty: FATCA fills part of this gap, but there is no broad tax data exchange deal
- Taiwan source income: You must report interest, dividends, and capital gains from Taiwanese accounts on your US tax return with no treaty benefits
Without a tax treaty, proper reporting matters even more. Therefore, the government expects full compliance with FBAR and FATCA rules from Americans with Taiwanese financial accounts.
FBAR Filing Deadline and Extension
The FBAR due date is April 15 of the year after the calendar year you are filing for, per 31 CFR 1010.306(c). FinCEN grants an auto extension to October 15. You do not need to ask for it.
You electronically file the FBAR through the BSA E-Filing system at FinCEN. The FBAR goes to FinCEN, not the IRS — it is separate from your tax returns. You can file on your own or have a preparer submit it for you.
FBAR Penalties for Not Filing
Penalties for failing to file the FBAR hit hard. They apply to all US persons with foreign accounts, including those with accounts in Taiwan. The IRS can assess fines per account, per year — so a person with several Taiwan accounts faces steep risk for even one missed filing year.
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 is one violation.
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 up to 5 years imprisonment under 31 USC 5322.
For a taxpayer with four Taiwan accounts totaling $36,508, non-willful penalties could reach $64,468 (four violations at $16,117 each) for a single year. See FBAR penalties: what happens if you don't file for further details.
What If You Missed Filing FBARs for Taiwan Accounts?
If you missed filing FBARs for prior years, the IRS offers several ways to catch up. You can use the Streamlined Filing Compliance Procedures, the Delinquent FBAR Submission Procedures, or the Voluntary Disclosure Practice. Come into compliance on your own before the IRS contacts you.
Streamlined Filing Compliance Procedures
The IRS Streamlined Filing Compliance Procedures let taxpayers catch up with reduced penalties:
- File the last 3 years of delinquent income tax returns
- File the last 6 years of delinquent FBARs
- Domestic Streamlined: pay a 5% offshore penalty on the highest aggregate value
- Foreign Streamlined: no penalty if you qualify as a non-resident
- Certify that your failure was non-willful
Americans living in Taiwan may qualify for the Foreign Streamlined path, which carries no penalty at all. Many US citizens who lived overseas and did not know about FBAR filing use this option.
Delinquent FBAR Submission Procedures
If your accounts earned no unreported income and you properly filed your tax returns, you may use the Delinquent FBAR Submission Procedures. The IRS may waive penalties if you already reported all income on your tax return.
IRS Voluntary Disclosure Practice
For willful non-compliance cases, the IRS Voluntary Disclosure Practice may apply. Contact a tax attorney or qualified tax professional before you pursue voluntary disclosure, as it involves civil and possibly criminal exposure.
Information You Need to File the FBAR
To file the FBAR for your Taiwan bank accounts, you need basic details about each account. Gather the following for each Taiwan account before you file:
- Account holder name: Your full legal name as it appears on the account
- Account number: The number assigned by the Taiwanese bank or institution
- Name and address of the institution: For example, "E.SUN Commercial Bank, Ltd., Taipei, Taiwan"
- Type of account: Bank, securities, or other
- Maximum value during the calendar year: Converted to USD using Treasury exchange rates
- Country: Taiwan
For jointly owned accounts, each US person reports the full value of the account. You do not split the balance with your spouse if they are not a US person.
Frequently Asked Questions
Do I need to report Taiwan bank accounts on the FBAR?
Yes. Any bank account, brokerage account, or other financial account located in Taiwan is a foreign financial account under 31 CFR 1010.350(c). You must file an FBAR if the aggregate value of all your foreign accounts exceeds $10,000 at any time during the calendar year.
Is the Taiwan Labor Pension Fund reportable on the FBAR?
Yes, in most cases. The Labor Pension Fund under the new system (新制) is a defined contribution account with a clear balance. FinCEN instructions say foreign retirement accounts are reportable. The old system (舊制) may or may not require reporting, depending on whether the employer holds funds in a separate account. Contact a tax attorney for guidance on your case.
How do I convert New Taiwan Dollars to USD for the FBAR?
Use the Treasury Department exchange rates published at fiscal.treasury.gov. Report the maximum value of each account during the year in USD. For a step-by-step guide, see how to calculate maximum account value for FBAR.
Does Taiwan share my account information with the IRS?
Yes. Taiwan signed a FATCA Model 2 IGA through the AIT-TECRO framework in 2016. Taiwanese banks report account data for American holders directly to the IRS. The IRS likely already has data on your Taiwan accounts.
Is there a US-Taiwan tax treaty that affects FBAR reporting?
No. There is no income tax treaty between the United States and Taiwan. Even countries with US tax treaties do not get FBAR exemptions. The FBAR is a FinCEN form under the Bank Secrecy Act, not a tax form, so treaties do not apply.
What happens if I don't file the FBAR for my Taiwan accounts?
Non-willful penalties reach $16,117 per account per year under 31 USC 5321. Willful penalties reach $100,000 or 50% of the balance. Criminal penalties include fines up to $250,000 and imprisonment under 31 USC 5322. See FBAR penalties guide.
Do I report my Taiwan Post (郵局) savings account?
Yes. Taiwan Post operates postal savings accounts that function as bank accounts. These are foreign financial accounts under FinCEN rules and must be reported on the FBAR like any other bank account in Taiwan.
Can I file the FBAR jointly with my Taiwanese spouse?
If both spouses are US persons and all accounts are jointly owned, you may file a joint FBAR. If your spouse is a Taiwanese national who is not a US person, only you file the FBAR. You report 100% of the value of any jointly owned account — do not split the balance.
Let FBAR Direct Handle Your Filing
Filing the FBAR for Taiwan accounts means gathering statements from banks like Bank of Taiwan, CTBC, E.SUN, and Cathay United. You then convert TWD balances to USD using Treasury rates and complete FinCEN Form 114. The process can be confusing without a US-Taiwan tax treaty to simplify matters.
Let FBAR Direct prepare your filing — you review and approve before we submit to FinCEN on your behalf. Upload your Taiwanese 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 21, 2026.
The information in this article is current as of April 21, 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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