Do I have to report Australian superannuation on the FBAR?

In the returns we prepare, yes. The FBAR exception for retirement plans is framed around US tax-qualified plans, and an Australian super fund is not one. A super account is a member account with a balance held by an institution in Australia, so we report each account as a foreign financial account whenever your foreign accounts together exceeded $10,000 at any time in the calendar year.

How do I convert Australian dollar balances for the FBAR?

Find the maximum value of each account during the calendar year in Australian dollars, using periodic statements, then convert that figure to US dollars at the end-of-calendar-year exchange rate. The IRS and FinCEN direct filers to the Treasury Reporting Rates of Exchange published by the Bureau of the Fiscal Service. Use the year-end rate for the year reported, not the current rate.

Can I still file an FBAR I missed years ago?

Yes. The IRS says that if it has not contacted you and you are not under investigation, late FBARs should be filed as soon as possible. They are filed through FinCEN's BSA E-Filing System with a reason for late filing. If your US tax returns are also missing or incomplete, the Streamlined Foreign Offshore Procedures cover six years of FBARs alongside three years of returns.

Is there a penalty under the Streamlined Foreign Offshore Procedures?

No. A taxpayer who meets the non-residency and non-willful requirements and files three years of returns, six years of FBARs and Form 14653, paying the tax and interest due, is not subject to failure-to-file, failure-to-pay, accuracy-related, information-return or FBAR penalties. Protection can be lost if a later examination finds the conduct was fraudulent or willful.

I live in the UK. Do I pay UK tax on Australian bank interest?

Normally, yes. GOV.UK states that a UK resident will normally pay tax on foreign income, which includes savings interest from abroad, and that it is usually reported in a Self Assessment tax return. Relief may be available where the same interest has been taxed in Australia, and some individuals may be eligible for Foreign Income and Gains relief. The UK and US figures should reconcile.

How do I find old super accounts now that I live in the UK?

The Australian Taxation Office operates a government service for locating lost and unclaimed super, available through its online services using your tax file number, with a paper search form as an alternative. It shows accounts reported under your name, including those classed as lost or paid across as unclaimed. Check the current process on the tax office website, then obtain statements for each calendar year.

Missed FBAR: Australian Accounts and Superannuation

Missed FBAR filings are the single most common US compliance gap we find when a US citizen or green-card holder moves to the UK after a long posting in Australia. The short answer is this: if the combined value of your Australian bank accounts, term deposits, brokerage account and superannuation funds exceeded $10,000 at any time in a calendar year, a FinCEN Form 114 was due for that year, and each unfiled year can still be filed late. How you file it late depends on whether your US income tax returns are also missing or incomplete.

The pattern is consistent across the returns we prepare for bankers, lawyers and mining and energy executives. They spent five to fifteen years in Sydney, Melbourne or Perth, moved to London, kept an everyday account for a rental or a mortgage offset, left a term deposit rolling over, forgot a share-trading account, and have two or three superannuation accounts from different employers that they have not looked at since they left. For FBAR purposes every one of those accounts is foreign.

What is the FBAR and who has to file it?

The FBAR is the Report of Foreign Bank and Financial Accounts, filed on FinCEN Form 114. It is an information report made to the US Treasury, not a tax return, and no tax is calculated on it. According to the IRS FBAR page at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar, a US person must file if they have a financial interest in, or signature or other authority over, at least one foreign financial account and the aggregate value of those accounts exceeded $10,000 at any time during the calendar year reported.

Three points in that definition matter for anyone with an Australian history. First, a US person includes a US citizen and a US resident, which takes in green-card holders, wherever in the world they live. Moving from Australia to the UK changes nothing. Second, the $10,000 figure is an aggregate. The IRS comparison page at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements describes the threshold as cumulative, so that if two accounts have a combined balance above $10,000 at any one time, both must be reported. Third, signature authority counts as well as ownership, which matters for anyone who still signs on a parent's account, a company account or a self-managed fund's bank account in Australia.

The IRS one-page FBAR summary at https://www.irs.gov/pub/irs-pdf/p4261.pdf puts the rule in a single sentence and adds a second obligation that is easy to overlook: the FBAR-related questions on the federal income tax return, such as Schedule B Part III of Form 1040, must be answered too. A return that answered No to the foreign account question while Australian accounts existed is itself part of the problem to be corrected.

When is the FBAR due and how is it filed?

The FBAR is due on April 15 following the calendar year reported. The IRS FBAR page confirms that filers who miss April 15 are allowed an automatic extension to October 15, with no request needed. The report for calendar year 2025 was therefore due on April 15, 2026 and is covered by the automatic extension until October 15, 2026. Anything for 2024 and earlier that has not been filed is already late.

The FBAR is not attached to the income tax return and is not sent to the IRS. It is filed electronically through FinCEN's BSA E-Filing System. The FinCEN FBAR page at https://www.fincen.gov/report-foreign-bank-and-financial-accounts states that individuals may file their own FBAR through the system without registering, while attorneys, CPAs and enrolled agents filing for clients must register as BSA E-Filers. Where a preparer files on your behalf, the authorisation is given on FinCEN Form 114a, which the IRS says is kept in your records and not submitted.

Which Australian accounts go on the FBAR?

The FBAR reports financial accounts maintained by a financial institution physically located in a foreign country. In the Australian files we work on, the reportable population is almost always wider than the client expects. The accounts we routinely find are:

Everyday transaction accounts kept open to receive rent, pay a mortgage or service a credit card.
Online savings accounts and mortgage offset accounts linked to an Australian property loan.
Term deposits, including ones that have rolled over automatically for years without the holder seeing a statement.
Share-trading or brokerage accounts, including the cash settlement account that sits behind them.
Joint accounts with a spouse or former spouse, where each US person reports the whole account value.
Accounts where you have signature authority but no ownership, such as a family member's account or a company account.
Superannuation accounts, covered in the next section.

Remember that the test is the aggregate. A dormant account holding a few hundred Australian dollars is reportable in any year in which all of your foreign accounts together, including your UK accounts, exceeded $10,000. For a high earner living in London with UK current accounts, savings and an investment platform, that threshold is passed every year before Australia is even considered, so every Australian account belongs on the form.

Does superannuation have to be reported on the FBAR?

This is the question that causes most of the missed filings, so it is worth being precise about what the official sources say and do not say. The IRS FBAR page lists a short set of exceptions, one of which covers foreign financial accounts held in a retirement plan of which you are a participant or beneficiary. That exception is framed around US retirement arrangements that qualify under the Internal Revenue Code. An Australian superannuation fund is not a US tax-qualified plan, so the exception does not, on its face, remove a super account from the FBAR. The IRS comparison of Form 8938 and FBAR requirements does not address foreign pension accounts in a dedicated line at all; its closest entries are that foreign financial accounts at foreign financial institutions are reportable on both forms, and that benefits under a foreign government's Social Security-type programme are reportable on neither.

Our preparation position follows from that. A superannuation account is a member account, in your name, with a balance, held with a financial institution located in Australia, and we report each one on the FBAR as a foreign financial account whenever the aggregate threshold is met. Some commentary argues that certain large pooled employer funds fall outside the form. Reporting an account that arguably was not required costs nothing, while leaving off one that was required is a violation, so for a filer catching up on missed years we disclose every account. A government social security payment such as the Australian Age Pension is different: it is a benefit, not an account.

What about several lost super accounts and self-managed funds?

Australian employers historically opened a new super account in their default fund for each new employee unless the employee nominated an existing one. Someone who changed firms four times in a decade can easily have four accounts. Each is a separate account for FBAR purposes and each is listed separately with its own institution name, account or member number and maximum value. A small, forgotten balance is not excused by its size, because the threshold is tested on the total.

Self-managed funds need more care. Where the member also runs the fund, the fund has its own Australian bank account and usually its own brokerage account, and the member typically has signature authority over both as well as an economic interest in what they hold. In those files we look through to the underlying accounts and consider reporting on both grounds, financial interest and signature authority. A self-managed fund can also raise additional US information-return questions beyond the FBAR. Those are analysed as part of return preparation and are outside the scope of this article, but a self-managed fund should never be treated as just another line on the form.

Separately, the US income tax treatment of superannuation, meaning contributions, growth inside the fund and eventual withdrawals, is complex and practitioners take different positions on it. The FBAR does not resolve that question and this article does not either. It has to be analysed fund by fund when the income tax returns are prepared, and the position taken should be consistent across every year filed.

How do you work out the maximum account value in US dollars?

The FBAR reports the maximum value of each account during the calendar year. The IRS comparison page sets out the method: use periodic account statements to determine the maximum value in the currency of the account, then convert that figure to US dollars using the end-of-calendar-year exchange rate. Both the IRS and FinCEN pages point filers to the Treasury Reporting Rates of Exchange for the conversion, which are published by the Bureau of the Fiscal Service and listed at https://fiscal.treasury.gov/reports-statements/treasury-reporting-rates-exchange/ for agencies and filers alike. The rate used is the year-end rate for the year being reported, not the rate on the day the balance peaked and not today's rate.

Two practical difficulties arise with Australian records. Australian institutions and super funds commonly issue statements on a financial year that ends mid-year, while the FBAR runs on the calendar year and the UK tax year ends in the spring. A June statement does not tell you the highest balance between January and December, so for bank and brokerage accounts we work from transaction listings, and for super we use the member statements either side of the calendar year together with any online balance history the fund provides. Where a precise peak cannot be established, a reasonable, documented estimate is used and the working papers are retained.

Do the same Australian assets also go on Form 8938?

Often, yes. Form 8938, the Statement of Specified Foreign Financial Assets, is a separate IRS form attached to the income tax return. Filing one does not replace the other. For taxpayers living abroad, the IRS comparison page gives the filing thresholds as total specified foreign financial assets of more than $200,000 on the last day of the tax year or more than $300,000 at any time during the year for unmarried filers and those married filing separately, and more than $400,000 on the last day of the tax year or more than $600,000 at any time for those married filing jointly.

The main differences that matter in an Australian catch-up file are these:

Where it goes: the FBAR is filed with FinCEN through BSA E-Filing, while Form 8938 is attached to the Form 1040 and follows its due date including extensions.
Threshold: the FBAR applies above $10,000 in aggregate, while Form 8938 has the much higher thresholds above for taxpayers abroad.
Scope: Form 8938 extends to certain non-account investment assets, such as foreign hedge funds and private equity funds, which the comparison page shows as reportable on Form 8938 only.
Conversion: both forms use a year-end exchange rate, calendar year-end for the FBAR and taxable year-end for Form 8938.
Penalties: the comparison page lists a Form 8938 penalty of up to $10,000 for failure to disclose, with an additional $10,000 for each 30 days of non-filing after IRS notice, up to a potential maximum of $60,000.

A senior executive with a term deposit, a brokerage account and a decade of employer and personal super contributions will usually exceed the Form 8938 thresholds on the Australian assets alone. The treatment of a foreign pension interest on Form 8938 is governed by that form's instructions, and in the returns we prepare superannuation balances are included when the thresholds are met.

What are the penalties for a Missed FBAR?

The IRS states plainly that filing an FBAR late or not at all is a violation and may subject you to penalties, that civil and criminal penalties may apply to both reporting and record-keeping violations, and that whether a penalty is asserted depends on the facts and circumstances. The framework has two tiers. A non-willful violation carries a capped civil penalty. A willful violation carries a far heavier one measured against the account balance. The IRS comparison page records the statutory base figures as up to $10,000 for a non-willful violation and up to the greater of $100,000 or 50 percent of account balances for a willful violation, and notes that civil penalty maximums are adjusted annually for inflation, so the amounts applying to an assessment today are higher than those base figures. The outcome turns on conduct, which is why establishing and documenting the non-willful facts honestly is the core of any late filing.

How do you file late FBARs from the UK?

There are two routes, and the choice depends on the state of your income tax returns. Note that the IRS no longer publishes a separate named procedure for delinquent FBARs. Its current guidance on the FBAR page is that if the IRS has not contacted you and you are not under civil or criminal investigation, you should file late FBARs as soon as possible to minimise potential penalties, following FinCEN's late-filing instructions or the specific compliance procedure you are using.

Route one applies where your US returns were filed on time and all Australian income, such as interest and dividends, was reported on them, but the FBARs were overlooked. Each late report is filed through the BSA E-Filing System, a reason for late filing is selected on the form, and an accurate explanation is given. FinCEN's FBAR page carries a dedicated Filing Late reference alongside the line item instructions.

Route two applies where income tax returns are also missing, or were filed without the Australian income. For a US person living in the UK, that usually means the Streamlined Foreign Offshore Procedures, which the IRS sets out at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states and whose requirements are specific:

Non-residency: a US citizen or green-card holder must have had no US abode and been physically outside the United States for at least 330 full days in one or more of the most recent three qualifying years.
Non-willful conduct: the failure must be due to negligence, inadvertence or mistake, or conduct that is the result of a good-faith misunderstanding of the law.
Returns: delinquent or amended income tax returns for the most recent 3 years, with all required information returns such as Form 8938.
FBARs: delinquent FBARs for the most recent 6 years for which the due date has passed, filed through BSA E-Filing by selecting Other as the reason for late filing and entering Streamlined Filing Compliance Procedures as the explanation.
Certification: Form 14653, signed, certifying eligibility, that all required FBARs have been filed and that the failures were non-willful, with a narrative of the facts.
Payment: all tax due and all applicable statutory interest is paid with the submission, which the IRS requires on paper.

A taxpayer who qualifies and complies is not subject to failure-to-file, failure-to-pay, accuracy-related, information-return or FBAR penalties under the foreign procedures. There is no offshore penalty on this route. The IRS adds two cautions: penalties already assessed for those years are not abated, and the protection can be lost if a later examination finds the original non-compliance was fraudulent or the FBAR violation was willful. The Form 14653 narrative therefore has to be accurate and complete, including how the Australian accounts arose and why they were not reported.

How do you trace old Australian accounts and super from the UK?

This is the part competitors rarely address and the part that takes the longest. A six-year FBAR lookback means reconstructing balances for accounts you may not have logged in to since you left. For bank, term deposit and brokerage accounts, the institution can normally reissue historical statements once you have re-established your identity, which from overseas often means certified identification documents and patience. Use the transaction histories of the accounts you know to find the ones you have forgotten.

For superannuation, the Australian Taxation Office runs a government service for finding lost and unclaimed super. Through its online services, which are accessed through the Australian government's online account once it is linked to the tax office, a member can see the super accounts reported under their tax file number, including accounts a fund has classed as lost and balances a fund has paid across to the tax office as unclaimed. A paper search form exists for people who cannot use the online route. Former temporary residents should be aware that super left behind after departure may have been transferred by the fund to the tax office as unclaimed money. We were unable to load the tax office's own guidance page while preparing this article, so confirm the current process directly on its website before relying on any step.

Worked illustration: a mining executive now in London

The following is an illustration only, with invented figures. A US citizen worked in Perth from 2012 to 2020 and has lived in London since 2021. She is unmarried. She has filed US returns each year reporting her UK salary but has never filed an FBAR and has never reported her Australian interest. At the end of the year being reviewed she holds a transaction account of A$6,000, a term deposit of A$150,000, a brokerage account of A$220,000 and three super accounts of A$310,000, A$48,000 and A$9,000, the last of which she had forgotten entirely. Assume, purely for the arithmetic and not as a Treasury rate, an exchange rate of A$1.50 to US$1.

The Australian total is A$743,000, or about US$495,333 at the assumed rate. That is far above the $10,000 FBAR threshold, so all six accounts are listed, including the A$9,000 super account worth about US$6,000, because the test is the aggregate and not the individual balance. It is also above the Form 8938 threshold for an unmarried taxpayer living abroad. Because her returns omitted the Australian interest and brokerage income, this is not a simple late-FBAR file. She has lived outside the United States throughout, so she meets the non-residency test, and on non-willful facts her route is the Streamlined Foreign Offshore Procedures: three years of amended returns with Form 8938, six years of FBARs, Form 14653, tax and interest paid, and no penalty.

What records must you keep?

The IRS requires records for each reportable account showing the name on the account, the account number, the name and address of the foreign bank, the type of account and the maximum value during the year. Bank statements or a copy of the filed FBAR can satisfy this if they contain that information. The records must be kept for five years from the due date of the FBAR. For Australian accounts, download and store statements each year, because online access is often lost once an Australian phone number or address lapses.

What about UK tax on Australian interest?

The US filings are only one side. GOV.UK guidance at https://www.gov.uk/tax-foreign-income states that if you are UK resident you will normally pay tax on your foreign income, that foreign income includes foreign investment income such as dividends and savings interest, and that you usually report it in a Self Assessment tax return. Interest on an Australian term deposit and dividends in an Australian brokerage account therefore need to be considered for UK purposes as well. The same guidance notes that you may be able to claim relief if you are taxed in more than one country, which is relevant where Australia has withheld tax from interest paid to a non-resident, and that some individuals may not have to pay UK tax on foreign income if they are eligible for Foreign Income and Gains relief. We prepare the US and UK returns from one set of reconstructed Australian figures so that the numbers agree.

What should you do next?

If you recognise your own history here, the order of work is straightforward. List every Australian account you have ever held, run the lost super search, obtain statements for the last six calendar years, and establish the full picture before filing anything, so that the correct route is chosen once. US-UK Tax prepares late FBARs, Form 8938 and complete Streamlined Foreign Offshore submissions for US citizens and green-card holders in the UK, alongside the UK Self Assessment return, so that old Australian accounts and superannuation are reported once, correctly, in both systems.