This page turns the rules into a routine. See the overview and the rules and numbers.
The Two-Tripwire Ledger Walk
The two tripwires are foreign accounts and cash receipts. Walk the account ledger yearly and the cash ledger as payments arrive.
- List the foreign accounts. Write down every account outside the U.S. that you or your business owns, co-owns or can sign on.
- Total the maximum values. Add the highest balance of each account during the year; the test uses the combined total.
- Cross the first tripwire. If the total topped $10,000 at any time, file FinCEN Form 114 online by 15 April (automatic extension to 15 October) and keep records five years.
- Match Schedule B. Answer Yes to the first question on Schedule B, Part III, line 7a for any foreign account interest, even with no FBAR due. Check Form 8938 separately.
- Scan the cash ledger. Look for over $10,000 in one transaction, in payments within 24 hours, or in installments within 12 months.
- Cross the second tripwire. File Form 8300 within 15 days, get the payer's correct taxpayer ID, send the customer statement by 31 January, and keep a copy five years.
- Keep cash whole. Splitting deposits or sales to stay under a report line is structuring, which is unlawful.
Common mistakes
- Filing the FBAR with the tax return or the IRS instead of FinCEN's BSA E-Filing System.
- Testing the $10,000 threshold account by account instead of on the combined total.
- Forgetting accounts with only signature authority, or held by the person's own entity.
- Answering No to Schedule B line 7a's first question because no FBAR is due.
- Missing a Form 8300 because a customer paid in cash installments.
- Skipping the 31 January customer statement, or mentioning a suspicious-activity box in it.
- Advising a client to deposit cash in smaller amounts.
When to talk to an attorney
A CPA cannot answer these legal questions. Talk to an attorney when:
- Foreign accounts were never reported and the owner may have acted willfully, or an IRS or FinCEN letter arrives.
- A cash pattern looks like structuring, or a bank asks about cash deposits or closes an account.
- A business may be a money services business, for example by cashing checks or moving money for others.
- A penalty assessment under 31 U.S.C. 5321 or IRC 6721 or 6722 is being contested.
Frequently asked questions
Do I file an FBAR if my foreign accounts add up to more than $10,000?
The law requires an FBAR from a U.S. person, including citizens, resident aliens and U.S.-formed entities, whose foreign accounts had a combined value above $10,000 at any time in the year. See FBAR for Indian bank accounts.
When is the FBAR due and where is it filed?
It is due 15 April after the calendar year, with an automatic extension to 15 October and no request needed. For 2026 accounts those dates are in 2027. File online with FinCEN, not with the IRS return.
Does a foreign retirement account go on the FBAR?
The exception covers foreign accounts held by a U.S. IRA or a 401(a), 403(a) or 403(b) plan. Foreign retirement accounts, such as a Canadian RRSP, are not within it. For the Indian provident fund, see the EPF page.
Is a check counted as cash for Form 8300?
A check drawn on the payer's own account is not cash. A cashier's check or money order of $10,000 or less can count as cash in the retail sale of a consumer durable, a collectible, or a travel or entertainment item, or when the recipient knows it is used to avoid a report.
A CPA can help with the payroll, tax and accounting side and works alongside the owner's attorney. For another FinCEN rule, see the Corporate Transparency Act guide.
Official sources
- IRS: Report of Foreign Bank and Financial Accounts (FBAR)
- IRS: Form 8300 and Reporting Cash Payments of Over $10,000
- IRS: Instructions for Form 8300
- IRS: Instructions for Schedule B
This page is a plain-language summary. The official source controls if there is any difference.