Do I still have to file an FBAR for UK accounts after moving back to the US?

Yes. The FBAR obligation depends on being a US person, not on where you live. If the combined value of your UK and other foreign accounts exceeded $10,000 at any time in a calendar year, you must file FinCEN Form 114 for that year through BSA E-Filing, due April 15 with an automatic extension to October 15. Moving back to the US does not end the requirement while the accounts remain open.

Can I use the Streamlined Foreign Offshore Procedures if I now live in the US?

Possibly. SFOP requires meeting the non-residency test, no US abode and at least 330 full days outside the US, in at least one of the most recent three years whose return due date, including a properly applied extension, has passed. If a full London year is still inside that window when you file, you can qualify despite now living in the US. Once it rolls out, you cannot.

What does the Streamlined Domestic Offshore Procedure cost?

Under SDOP you pay a Title 26 miscellaneous offshore penalty of 5 percent of the highest aggregate year-end balance or value of your foreign financial assets during the covered tax return and FBAR period, in addition to any tax and interest due on amended returns. You must also have previously filed US returns for the most recent three years where required, and you certify non-willful conduct on Form 14654.

How do I file a late FBAR if all my income was already reported?

If your UK income was fully reported on timely filed returns and only the FBARs are missing, file each outstanding year electronically through FinCEN's BSA E-Filing System and give a factual reason for late filing. The IRS advises filing late FBARs as soon as possible. Do not rely on the former Delinquent FBAR Submission Procedures page, which the IRS withdrew around July 2026.

Does HMRC need anything from me when I leave the UK?

Usually yes. You should file a Self Assessment return for the tax year you leave, including the residence pages, and claim split-year treatment if you meet one of the statutory cases. GOV.UK explains that the year is normally split into a resident and a non-resident part. You should also tell HMRC you have left and update your UK banks, ISA manager and pension providers.

Is my UK ISA taxable in the US after I move back?

Generally yes. The ISA wrapper has no US tax status, so interest, dividends and gains inside it are reportable on your US return. UK-domiciled funds held in a stocks and shares ISA are usually PFICs, which require Form 8621 and can attract harsh default US tax treatment. The ISA is also a foreign financial account that counts toward the FBAR and Form 8938 thresholds.

Missed FBAR After Moving Back to the US From the UK

A missed FBAR after moving back to the US from the UK is fixable, but the route depends on timing more than most people expect. If you are a US citizen who kept UK current accounts, savings, an ISA, a brokerage account or a pension open after relocating from London, you generally have to report them on FinCEN Form 114 for every year the combined balance of your foreign accounts went above $10,000 at any point. If your income was fully reported and only the FBARs are missing, you usually file them late through FinCEN's BSA E-Filing System with a reason statement. If income from those accounts was left off your returns, the Streamlined Filing Compliance Procedures are the normal fix, and whether you qualify for the Foreign or the Domestic version depends on which three tax years are in the look-back window on the day you file.

That last point is where returning bankers, executives and investors get caught. The years you spent in London can make you eligible for the penalty-free foreign track today, and a single passing filing deadline can push you into the domestic track, with its 5 percent miscellaneous offshore penalty, a few months later. In the returns we prepare for people who have moved back from the UK, the failure mode we see most often is not the missing form itself. It is waiting until the London years have rolled out of the window.

What Is the FBAR and Why Does It Follow You Home?

The FBAR, formally FinCEN Form 114, is an annual report of foreign financial accounts that a US person must file when the aggregate value of those accounts exceeded $10,000 at any time during the calendar year. The IRS summarises the rule at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar. The obligation attaches to US citizenship and residence, not to where you live. It applied while you were in London, and it continues to apply now that you are back in New York, Boston or San Francisco, for as long as the UK accounts stay open.

Three features of the rule matter most for someone who has just returned from the UK:

Aggregation: the $10,000 test is applied to the combined value of all foreign accounts, not to each account on its own. A UK current account at 4,000 pounds, a savings account at 3,000 pounds and a cash ISA at 2,000 pounds can together cross the line, depending on the exchange rate.
Financial interest and signature authority: you report accounts you own and accounts over which you have signature or other authority, which can include a UK company account you still control or an account you hold jointly with a spouse or parent.
Maximum value: each account is reported at its highest value during the calendar year, converted to US dollars. FinCEN's filing instructions direct filers to the Treasury Reporting Rates of Exchange for the last day of the calendar year, published at https://www.fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange/.

The FBAR is due April 15 following the calendar year reported, and FinCEN grants an automatic extension to October 15 without any request. It must be filed electronically through FinCEN's BSA E-Filing System at https://bsaefiling.fincen.gov. It is not attached to your Form 1040 and is not sent to the IRS.

Which UK Accounts Still Count After You Move Back?

In practice almost every UK financial account a returning executive leaves open is in scope. The accounts we most often find unreported after a London posting are:

High-street current and savings accounts kept open for direct debits, a UK mobile contract or a rental property.
Cash ISAs and stocks and shares ISAs. The ISA wrapper is a UK concept only; for US purposes the account is a foreign financial account and its income is generally taxable.
UK brokerage and investment platform accounts holding UK-domiciled funds, ETFs or listed shares.
Workplace and personal pension arrangements, including SIPPs, which are foreign financial accounts for FBAR purposes.
Accounts linked to UK property, such as a letting agent's client account in your name or a mortgage offset account with a positive balance.
Joint accounts with a UK spouse, and company accounts where you retain signature authority after leaving a UK employer or your own UK company.

Closing accounts after the fact does not remove the reporting obligation for the years they were open. It simply stops the problem from growing.

Form 8938 Thresholds Drop Sharply Once You Live in the US

Form 8938, the Statement of Specified Foreign Financial Assets, is a separate IRS form filed with your tax return, and its thresholds change when you come home. According to the IRS comparison at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements, an unmarried taxpayer living in the US files when specified foreign assets are more than $50,000 on the last day of the tax year or more than $75,000 at any time during the year. For married couples filing jointly and living in the US, the figures are more than $100,000 at year end or more than $150,000 at any time.

Taxpayers living abroad have much higher thresholds: more than $200,000 at year end or $300,000 at any time for unmarried filers, and more than $400,000 at year end or $600,000 at any time for joint filers. The higher figures only apply if you meet the presence or residence test set out in the Form 8938 instructions. In the year you move back, many filers will not meet that test, so the lower domestic thresholds apply. A returning banker with a UK pension, an ISA portfolio and cash savings can go from no Form 8938 obligation in London to a clear filing requirement in the first full year back, without any change in wealth.

Missed FBAR With No Unreported Income: Filing Late Through BSA E-Filing

Some returning clients filed every US return on time while in London, claimed foreign tax credits or the foreign earned income exclusion correctly, and reported all interest and dividends, but never filed an FBAR. If that describes you, you are not reporting any new income; you are only catching up on an information report.

The IRS page on FBARs tells people who are not under a civil examination or criminal investigation to file late FBARs as soon as possible to keep potential penalties to a minimum. In practice that means filing each missing year through BSA E-Filing and selecting and explaining the reason for late filing. The explanation should be factual and specific: that you were a US citizen resident in the UK, that your income from the accounts was reported on timely filed returns, that you were unaware of the separate FinCEN requirement, and that you have now filed all outstanding years.

One point needs to be clear. The IRS used to publish a page called the Delinquent FBAR Submission Procedures. That page was withdrawn around July 2026, and it should not be treated as a live, named IRS programme. Late FBARs are now filed through BSA E-Filing with a reason statement, or as part of a Streamlined submission where income was also missed. Anyone who tells you to file under the old procedure by name is working from out-of-date guidance.

Missed FBAR and Unreported UK Income: Which Streamlined Track Applies?

If the missing FBARs come with missing income, such as ISA interest, dividends from UK funds, or gains on disposals in a UK brokerage account, the usual route for non-willful taxpayers is the Streamlined Filing Compliance Procedures described at https://www.irs.gov/individuals/international-taxpayers/streamlined-filing-compliance-procedures. The IRS defines non-willful conduct as conduct due to negligence, inadvertence or mistake, or a good faith misunderstanding of the law. Every streamlined return needs a valid Social Security number, and you cannot use the procedures if the IRS has already opened a civil examination of your returns or you are under criminal investigation.

There are two versions, and the difference is significant for someone who has moved back.

Streamlined Foreign Offshore Procedures (SFOP): for a US citizen, you must meet the non-residency test in at least one of the most recent three years for which the US return due date, or properly extended due date, has passed. The test is having no US abode and being physically outside the US for at least 330 full days in that year. You file three years of returns or amended returns, six years of FBARs and Form 14653. There is no miscellaneous offshore penalty. The IRS page is https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states.
Streamlined Domestic Offshore Procedures (SDOP): for taxpayers who fail the non-residency test for all three years. You must have previously filed a US return for each of the most recent three years where required. You file amended returns for three years, six years of FBARs and Form 14654, and pay a Title 26 miscellaneous offshore penalty equal to 5 percent of the highest aggregate year-end balance of the foreign financial assets in the covered period. The IRS page is https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-in-the-united-states.

Streamlined returns are processed like any other return and remain subject to normal audit selection. The IRS does not acknowledge receipt of a streamlined submission, so keep proof of mailing and filing.

The Domestic vs Foreign Year-Counting Trap After You Return

The SFOP window is not fixed to the years you lived in London. It is the most recent three tax years whose due date has passed at the moment you file, and it moves forward every time a new due date goes by. As soon as your last full London year drops out of that window, you lose the foreign track, even though nothing about your facts has changed.

Two practical consequences follow. First, a filing extension on your current-year return can help or hurt: the IRS counts the properly applied extended due date, so an extended year does not enter the window until the extended deadline passes, which can keep an older London year inside it for longer. Second, the domestic track requires previously filed returns. If you stopped filing US returns in London because you assumed the foreign earned income exclusion made them unnecessary, and your London years have already rolled out of the window, you may not fit either streamlined track neatly. That situation needs a different compliance route and should be assessed before anything is filed.

Worked Scenario: A Banker Who Moved Back in July 2024

The following is an illustration only. The figures are hypothetical, and any exchange rate used is an assumption for the example rather than a published Treasury rate.

James is a US citizen who worked for an investment bank in London from 2017 until 30 June 2024, then relocated to the firm's New York office in July 2024. He filed US returns every year with foreign tax credits and reported his salary, but he never filed an FBAR and never reported the interest in his cash ISA or the dividends and gains in his stocks and shares ISA, which held UK-domiciled funds. He kept a UK current account, both ISAs and his UK workplace pension after moving.

2023: James lived in London all year, had no US abode and spent well over 330 full days outside the US. He meets the non-residency test for 2023.
2024: He was in London until the end of June and in New York from July. He cannot meet the 330-day test for 2024, and by the second half of the year he had a US abode. 2024 is a dual year: part-year abroad, part-year at home.
2025: James lived in New York all year. He does not meet the test.

Assume James did not extend his 2025 return and files his streamlined submission in September 2026. The most recent three years with a passed due date are 2023, 2024 and 2025. He met the non-residency test in 2023, so he qualifies for SFOP, files amended returns for 2023 to 2025, files FBARs for the six most recent years with a passed FBAR due date, and pays no miscellaneous offshore penalty.

Now assume James waits. Once the 2026 return due date passes, the window becomes 2024, 2025 and 2026. He meets the non-residency test in none of them, so SFOP is gone. Because he filed original returns every year, he still fits SDOP, but he now pays 5 percent of the highest aggregate year-end balance of his UK accounts and pension across the covered years. On an illustrative combined UK balance equivalent to $900,000, that is a $45,000 penalty that simply did not exist a few months earlier. The delay, not the underlying error, created the cost.

Note also that his 2024 return, as the move year, needs Form 8938 reviewed against the lower domestic thresholds, and his 2025 return almost certainly requires Form 8938 given the size of his UK assets.

FBAR Penalties After Bittner: Per Report, Not Per Account

The penalty exposure for non-willful FBAR failures was narrowed by the Supreme Court in Bittner v. United States, decided on 28 February 2023 and available at https://www.supremecourt.gov/opinions/22pdf/21-1195_h3ci.pdf. The Court held that the non-willful civil penalty applies per report, meaning per annual FBAR not filed or filed incorrectly, and not per account listed on the report. For a returning executive with eight UK accounts across six years, that distinction is the difference between a penalty calculated on 48 accounts and one calculated on six reports.

The statutory maximum non-willful penalty is adjusted for inflation, so we do not quote a single figure here. Willful violations are treated far more severely and are outside the streamlined procedures altogether. The IRS FBAR page also notes that both civil and criminal penalties can apply to reporting and recordkeeping violations, which is why the reason statement and the non-willful certification must be accurate rather than boilerplate.

Why UK Banks Have Already Made Your Accounts Visible

Under FATCA and the US-UK intergovernmental agreement, UK financial institutions identify account holders with US indicia, such as a US birthplace, US address or US phone number, and report them to HMRC, which passes the information to the IRS. The IRS overview of FATCA is at https://www.irs.gov/businesses/corporations/foreign-account-tax-compliance-act-fatca. When you update your UK bank with a New York address after moving, you strengthen the US indicia on file.

The Common Reporting Standard works in parallel for other countries of residence, but for a US citizen the FATCA channel is the one that matters. The practical point is simple: the IRS may already hold data on your UK balances. Streamlined relief depends on filing before the IRS contacts you, so a letter or examination notice closes the door on the procedures.

ISAs and UK Funds That Stay in Place: The PFIC Problem

The second gap competitors rarely address is what happens to the investments you leave behind. A stocks and shares ISA holding UK-domiciled OEICs or ETFs is tax-free in the UK, but those funds are usually passive foreign investment companies (PFICs) for US purposes. A PFIC is a non-US company whose income or assets are mainly passive, and US shareholders face punitive default taxation of distributions and gains, plus annual reporting on Form 8621, described at https://www.irs.gov/forms-pubs/about-form-8621.

While you lived in London, some filers treated the ISA as invisible because the UK does. Once you are back in the US, the UK tax shelter no longer offsets anything on your US return, yet the US tax cost continues every year the funds are held. When we prepare a streamlined or late filing for a returning client, we compute the PFIC position for the covered years and then look at whether continuing to hold UK funds makes sense going forward. The FBAR catch-up and the PFIC catch-up belong in the same package; filing one without the other leaves the returns incomplete.

UK-Side Housekeeping: Self Assessment and Split-Year Treatment

Cleaning up the US side is only half the job. In the UK tax year in which you leave, HMRC's guidance at https://www.gov.uk/tax-foreign-income/residence explains that when you move in or out of the UK the tax year is usually split into two parts, a resident part and a non-resident part, so that UK tax on foreign income is based on the time you were living in the UK. Split-year treatment is not automatic in every case. You need to meet one of the statutory cases under the Statutory Residence Test and state which case applies on your Self Assessment return.

File a Self Assessment return for the tax year of departure, including the residence pages, and claim split-year treatment if you qualify.
Tell HMRC you have left the UK and update your UK banks, pension providers and ISA manager with your new status and address.
Check whether you can keep subscribing to your ISA: new subscriptions generally require UK residence, while an existing ISA can usually be held after you leave.
Keep UK tax computations and P60 or P45 figures together, because they support the foreign tax credit claimed on your US return for the move year.

UK rental income, UK interest and other UK-source income can remain taxable in the UK after you leave, and it stays reportable on your US return with foreign tax credit relief where available. Keeping the two countries' filings consistent is what makes a streamlined submission credible.

A Practical Sequence for Fixing a Missed FBAR After Returning

Pull statements for every UK account for at least the last six calendar years and record the maximum value in each year.
Establish, year by year, whether you met the 330-day non-residency test and when you acquired a US abode, and map those years against the current look-back window.
Decide whether any income was omitted. If none was, file late FBARs through BSA E-Filing with a reason statement. If income was omitted, prepare a streamlined submission under the track the window allows.
Review Form 8938 and Form 8621 for every covered year, applying the domestic thresholds from the year of return.
Reconcile UK Self Assessment for the departure year so the foreign tax credits on the US side are supported.
Decide which UK accounts to keep, close or consolidate, and put ongoing FBAR and Form 8938 reporting on the annual filing calendar.

The single most valuable step is the second one. Once you know exactly which of your years meets the non-residency test, you know how long the foreign track stays open and how quickly the submission needs to be filed.