Do I need to report a Chinese bank account I can no longer access?

Yes, if the account still exists and you have a financial interest in it. Losing online access, a dormant classification or difficulty moving RMB out of the mainland does not close the account for FBAR purposes. Report the highest balance for each year, converted at the Treasury year-end rate, until the bank confirms in writing that the account is closed and the balance has been paid out.

Which exchange rate converts RMB and New Taiwan dollars on a late FBAR?

Use the US Treasury Reporting Rates of Exchange for 31 December of each year being reported. For 2025 the recorded rates are 6.998 renminbi and 31.324 New Taiwan dollars per US dollar. Each earlier year in a six-year catch-up uses its own year-end rate, not the 2025 figure, the bank's rate or the HMRC rate used for UK Self Assessment.

Is a Taiwanese brokerage account and its settlement account one FBAR entry or two?

Two. A Taiwanese securities account is paired with a separate bank settlement account in the holder's name, and each is a financial account in its own right. The settlement account can hold large cash balances between trades or after dividends, so report its highest balance separately rather than assuming it is covered by the brokerage line.

Does filing late FBARs tell HMRC about my Chinese or Taiwanese income?

No. The FBAR goes to FinCEN and the Streamlined filings go to the IRS. If RMB interest or Taiwanese dividends are missing from your UK Self Assessment returns, HMRC needs its own disclosure. We prepare both together so that income figures, exchange rates and double taxation relief claims agree across the two countries.

Can a US citizen living in London use the Streamlined Foreign Offshore Procedures?

Usually, yes. You qualify on residence if, in at least one of the three most recent years with a passed due date, you had no US abode and spent at least 330 full days outside the United States. The failure must also be non-willful. Qualifying filers submit three years of returns, six years of FBARs and Form 14653, with no penalty.

Are mainland mobile payment wallet balances reportable on the FBAR?

FinCEN has not issued definitive guidance on stored-value wallet balances. Where the wallet only draws from a linked bank card, the bank account is what gets reported. Where it holds a standing balance or sweeps cash into a money-market fund product, we generally report it with a documented explanation, because over-disclosure carries little downside.

Missed FBAR: Chinese and Taiwanese Accounts Guide

A Missed FBAR on mainland Chinese or Taiwanese accounts is corrected by filing the overdue FinCEN Form 114 reports through the BSA E-Filing System, either on their own with a reason for lateness if every dollar of income from those accounts already appears on your US returns, or inside the Streamlined Foreign Offshore Procedures if it does not. For a US person living in the UK whose failure was non-willful, the Streamlined Foreign route carries no penalty. The law is the same for every country. What makes the China and Taiwan versions harder is the evidence: several sub-accounts sitting behind one card number, RMB balances that cannot easily leave the mainland, statements that often need a branch visit, and a currency conversion that must use the US Treasury year-end rate for each separate year.

This guide is written for the reader we see most often with this problem. A US citizen or green card holder now settled in London or elsewhere in the UK, often a dual national, frequently a banker or senior executive who spent several years on a Shanghai, Beijing, Shenzhen or Taipei posting, or someone with family roots on the mainland or in Taiwan who has held local accounts since before adulthood. The balances are rarely small. In the returns we prepare for this group, the FBAR gap is usually six or more years old and sits alongside interest, fund distributions or dividends that never reached Form 1040.

Which Chinese and Taiwanese accounts count for a Missed FBAR?

The test is set out on 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, foreign financial accounts whose aggregate value exceeded $10,000 at any time during the calendar year. Whether an account earned taxable income is irrelevant, and so is the currency it is held in. A US dollar deposit in a Shanghai branch is a foreign account exactly as an RMB deposit is, because the location of the institution decides the question, not the denomination. FinCEN describes the filing mechanics, including the fact that individuals can file through BSA E-Filing without registering, at https://www.fincen.gov/report-foreign-bank-and-financial-accounts.

On the mainland, the accounts that turn up in our files fall into these groups:

RMB demand deposits attached to a debit card, together with the time-deposit tranches booked beneath the same card
Fixed-term RMB deposits and large-denomination certificates of deposit, which often roll over automatically for years after the holder has left
Bank-distributed wealth management products and structured deposits held in the bank's own custody records
US dollar or sterling sub-accounts at a mainland bank, which remain foreign accounts for FBAR purposes
Securities and fund accounts with a mainland broker or fund distributor, plus the bank settlement account linked to them
Housing provident fund and social insurance personal accounts accumulated during local employment, discussed separately below
Stored-value balances and money-market sweeps inside a mobile payment wallet, also discussed below

In Taiwan the shape is different but the number of reportable items is just as high:

New Taiwan dollar demand and time deposits, usually recorded in a single passbook that covers several sub-accounts
Foreign-currency deposits at a Taiwanese bank, commonly US dollar or Australian dollar savings booked for the interest rate differential
A securities account with a Taiwanese broker, which is always paired with a separate bank settlement account in the same name
Savings-type life insurance policies with a cash surrender value, which need a line-by-line review because the FBAR rules reach some cash-value policies
Postal savings passbook accounts, which are financial accounts like any commercial bank deposit
Labour pension individual accounts built up through Taiwanese employment, which need separate analysis rather than an assumption either way

Why does one Chinese bank card hide several accounts?

The most common error we correct on mainland files is reporting a card instead of an account structure. A mainland debit card is a front door to a customer profile. Behind it there is usually a current sub-account, any number of fixed-term tranches opened over the years, a foreign-currency sub-ledger, and positions in wealth products bought through the banking app. Reporting only the current balance on the card statement misses the time deposits that often hold most of the money.

Our practice is to request the full customer-level statement and to list every separately numbered sub-account that the bank's records show. Where the bank can produce only the card number with a combined position, we report under that card number using the highest combined value, and we keep the bank's written explanation with the file. The choice matters less than consistency: the same structure should be reported the same way across all six years, because an IRS reviewer comparing years will notice an account that appears and disappears without explanation.

Taiwanese passbooks raise the same issue from a different direction. A comprehensive passbook may record a demand balance, two or three fixed deposits and a foreign-currency savings line under one booklet. The brokerage pairing adds another layer: the securities account holds the shares, the linked bank account holds the cash from sales and dividends, and both are reportable on their own lines. We regularly see brokerage balances reported while the settlement account, which can hold large sums between trades, is left off.

How do you convert RMB and New Taiwan dollars for the FBAR?

FBAR values are converted with the Treasury Reporting Rates of Exchange, the US government's official rates for converting foreign currency into dollars, published quarterly on the Fiscal Data site at https://fiscaldata.treasury.gov/datasets/treasury-reporting-rates-exchange/treasury-reporting-rates-of-exchange. For FBAR purposes the rate used is the one for the last day of the calendar year being reported, applied to the highest balance the account reached in that year. The bank's own rate, the rate on the day of the peak balance and the HMRC rate are all the wrong numbers for this form.

For the 2025 calendar year, the Treasury year-end rates recorded for 31 December 2025 in the machine-readable feed at https://api.fiscaldata.treasury.gov/services/api/fiscal_service/v1/accounting/od/rates_of_exchange are 6.998 Chinese renminbi and 31.324 New Taiwan dollars to one US dollar. Those two figures apply only to the 2025 report. Each of the five earlier years in a six-year catch-up has its own 31 December rate, and the renminbi in particular moved enough across the period that applying one year's rate to every year can push an account across or below the $10,000 aggregate line in the wrong year.

Readers with UK filing obligations will meet a second and third conversion in the same file. The interest, dividends and gains themselves are converted under the US income rules for Form 1040, and HMRC has its own published exchange rates for Self Assessment. We keep three separate conversion schedules for these clients so that a figure prepared for one purpose is never copied into another form by mistake.

Does money you cannot move out of mainland China still need reporting?

Yes. The FBAR reports accounts, not liquidity. Mainland rules limit how much foreign currency an individual can buy each year and require documentation before larger sums are sent offshore, and in practice that means many returning executives leave a substantial RMB balance behind because the paperwork to bring it out was never completed. None of that changes the reporting position. If you have a financial interest in the account, the highest balance in the year is reported in full, converted at the Treasury year-end rate, even if moving it to London would take months.

The same answer applies to accounts the bank has classified as dormant or restricted after a long period without activity. A restriction on use is not a closure. Until the bank confirms in writing that the account has been closed and the balance paid out, we treat it as open. The US income consequences follow the same logic: interest credited to an RMB deposit is taxable on your US return when it is credited to you, whether or not you can bring it out of the country.

How should housing provident fund, social insurance and Taiwan labour pension accounts be handled?

These balances are not US retirement accounts and should never be described as if they were. They are local programmes with their own rules, and FinCEN has not published guidance that addresses them by name. That leaves a judgement to be made and documented for each client.

A mainland housing provident fund account is built from employer and employee contributions during local employment, administered by a municipal centre and usually held at a designated bank in the employee's name. Withdrawal is permitted on specified events, which in some cities include permanently leaving the mainland. Because the balance typically sits at a financial institution in the individual's name, in the returns we prepare we generally take the conservative course and include it, with a note in our file explaining the basis. A social insurance personal account is often different in substance: it is a contribution record maintained by the authorities rather than a deposit the individual controls, and where the facts show that, we record our reasoning for treating it as outside the form.

A Taiwan labour pension individual account is administered by a government agency and accumulates employer contributions, sometimes with voluntary employee top-ups. The analysis turns on who holds the funds, whether there is a balance the individual can draw on, and how the agency describes the account. We review the agency's annual statement before deciding, and we apply the same treatment in every year of the catch-up. A lump sum already received from either account is a separate income question for both returns.

What about mobile payment wallet balances?

FinCEN has not issued definitive guidance on whether stored-value balances in mainland mobile payment wallets are foreign financial accounts. Any article that states a firm rule is going further than the official position allows. What we can do is look at what the balance actually is.

If the wallet is only a pass-through, drawing money from a linked bank card at the moment of payment, the reportable account is the bank card account, which is already on the FBAR
If the wallet holds a standing cash balance in your name, the arguments for reporting it are stronger, and we generally include it with a note explaining the approach
If the wallet sweeps idle cash into a money-market fund product, that position looks like a fund account held through a financial institution, and we report it
If balances are small but push the aggregate over $10,000 in a borderline year, we disclose rather than argue, because the downside of over-reporting is negligible

Missed FBAR or unreported income: which route fits?

The route depends on one question more than any other: did the income from these accounts reach your US returns? The IRS page that once described a stand-alone late FBAR procedure was withdrawn around 1 July 2026, so a stand-alone late filing now rests on FinCEN's BSA E-Filing late-filing process rather than a named IRS programme. We built the decision list below from the cases we see:

If all interest, fund income, dividends and gains from the Chinese and Taiwanese accounts are already on your US returns and no additional US tax is due, then file the delinquent FBARs through BSA E-Filing and select and explain a reason for late filing
If RMB deposit interest or Taiwanese dividends never reached Form 1040, you were non-willful, and you meet the non-residency test, then use the Streamlined Foreign Offshore Procedures: three years of returns, six years of FBARs, Form 14653, and no penalty
If you fail the non-residency test because you were back in the US for the relevant years, then the Streamlined Domestic Offshore Procedures are the comparison point, with their own conditions and a 5% miscellaneous offshore penalty that applies to that domestic programme only
If the IRS has already contacted you about these years, or the facts point to deliberate concealment, then the streamlined procedures are not the starting point and the case needs specialist representation before anything is filed
If you own shares in a mainland or Taiwanese company rather than only holding accounts, then information returns such as Form 5471 may also be in scope and the catch-up becomes a full entity review
If your only connection is signature authority over a former employer's mainland accounts, then check the employer-related exceptions before assuming you must file, and confirm the dates your authority actually ended

For UK residents the non-residency limb is usually the easy part. The IRS explains at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states that a US citizen or green card holder qualifies if, in at least one of the most recent three years with a passed due date, they had no US abode and were physically outside the United States for at least 330 full days. The same page sets out the filing package: delinquent or amended returns for the most recent three years marked Streamlined Foreign Offshore, FBARs for the most recent six years filed through BSA E-Filing, full payment of tax and interest, and a signed Form 14653 certification. The page also confirms that a qualifying taxpayer will not face FBAR or information return penalties for the submitted years.

The certification is where China and Taiwan files need the most care. Form 14653 asks for a narrative explaining why the accounts were not reported. A generic paragraph is weak. A specific account of what happened is strong: the posting ended, the payroll account kept receiving a final bonus, the time deposits rolled over automatically, the employer's tax equalisation provider dealt only with salary, and nobody mentioned the FBAR. The facts must be true and consistent with the records you are filing.

Will the IRS learn about my Chinese or Taiwanese accounts anyway?

The US Treasury list of FATCA intergovernmental agreements at https://home.treasury.gov/policy-issues/tax-policy/foreign-account-tax-compliance-act shows mainland China as an agreement in substance under the Model 1 framework, and Taiwan as a signed Model 2 agreement. The Taiwan entry carries a footnote explaining that, under the Taiwan Relations Act, the parties are the American Institute in Taiwan and the Taipei Economic and Cultural Representative Office in the United States. In broad terms, a Model 2 arrangement has local institutions reporting directly to the IRS, while a Model 1 arrangement routes information through the local tax authority.

We do not build any plan on whether a particular bank has reported a particular account. Long-term account holders often find they signed a US status declaration at a branch visit they barely remember. The practical point is that the non-willful certification has to be accurate whatever the IRS already holds, and a catch-up filed before contact is in a far stronger position than one filed after a letter arrives.

What does the UK side require for the same accounts?

A UK resident is taxed in the UK on foreign income, and RMB deposit interest or Taiwanese dividends are no exception. The remittance basis for non-domiciled individuals ended on 6 April 2025 and was replaced by the four-year foreign income and gains regime, which is aimed at people newly arriving in the UK. For most of the long-settled London residents we work with, Chinese and Taiwanese income is therefore taxed as it arises and belongs on the foreign pages of the Self Assessment return.

Two points catch people out. First, years before April 2025 in which a client claimed the remittance basis may have left unremitted RMB income outside UK tax at the time, and later transfers to London can have consequences of their own, so the history needs reconstructing rather than assuming. Second, fixing the US position tells HMRC nothing. HMRC runs its own route for disclosing unreported offshore income, and where the UK returns are also incomplete we prepare that disclosure alongside the US filings so that the figures, exchange rates and credits match across both countries and the same interest is not taxed twice without relief.

Worked scenario: a London executive after a Shanghai and Taipei career

Illustration only. The figures below are invented for this example; the exchange rates are the Treasury rates recorded for 31 December 2025, used for the 2025 year alone.

The client is a US citizen who worked in Shanghai and then Taipei for a decade before moving to London in 2021, where she has lived ever since. She filed US returns every year but reported only her salary. In 2025 her mainland accounts reached these highest balances: a current sub-account of 35,000 renminbi, rolling time deposits of 420,000 renminbi, a wealth management product of 600,000 renminbi and a housing provident fund balance of 180,000 renminbi. In Taiwan her highest balances were 1,900,000 New Taiwan dollars on deposit, 3,200,000 in a brokerage account and 450,000 in its settlement account.

At 6.998 renminbi to the dollar, the mainland figures convert to roughly 5,001, 60,017, 85,739 and 25,722 US dollars, about 176,479 dollars in total. At 31.324 New Taiwan dollars to the dollar, the Taiwanese figures convert to roughly 60,656, 102,158 and 14,366 dollars, about 177,180 dollars in total. Seven reportable lines, comfortably above the aggregate threshold, and the same exercise has to be repeated with each earlier year's own rate.

The time-deposit interest and the Taiwanese dividends were never on Form 1040, so a late FBAR on its own would not cure the problem. She meets the 330-day test in every recent year and the failure was non-willful, so we prepare the Streamlined Foreign Offshore package: amended returns for the three most recent years with a passed due date, six FBARs covering every account in every year, and a Form 14653 narrative tied to her employment history. On the UK side, the same income is checked against her Self Assessment returns and any gaps are disclosed to HMRC. Under the Streamlined Foreign terms there is no penalty; the cost is the tax and interest on the omitted income and the work of rebuilding the records.

How do you rebuild six years of mainland and Taiwan records from London?

Records are the real constraint. Many mainland banks require a mainland mobile number for online access and an in-person visit for certified historical statements, and Taiwanese banks often hold older passbook history only at the branch. The process we use runs in this order:

Step 1: List every card, passbook, brokerage login, wallet and employer-related account, including anything opened for a single purpose such as rent or school fees
Step 2: Ask each bank for customer-level statements covering all six years, specifying every sub-account and product, not just the card number
Step 3: Where a branch visit is needed, plan one trip or arrange a properly authorised local representative, so that requests are not made piecemeal
Step 4: Identify the highest balance in each sub-account for each calendar year; where only month-end figures exist, take the highest and keep a note of the method
Step 5: Convert each maximum with that year's 31 December Treasury rate and test the aggregate against the $10,000 line year by year
Step 6: Reconcile interest, fund income, dividends and gains to the US returns already filed, to decide between a stand-alone late FBAR and the Streamlined Foreign route
Step 7: Reconcile the same income to the UK returns, then file the US package and any HMRC disclosure together so the numbers agree
Step 8: Keep the statements, conversions and reasoning for at least five years from each FBAR due date, the IRS record-keeping period

Where to start if you have a Missed FBAR on mainland or Taiwan accounts

Start with the inventory, not the forms. A single list of every account behind every card and passbook, with the highest balance for each year, answers most of the hard questions: whether you crossed the threshold, which years are affected, whether income is missing from Form 1040, and therefore which route applies. In the returns we prepare for UK-resident clients with mainland and Taiwanese history, the filing itself is the shortest part of the work. Getting the statements, choosing a defensible treatment for the provident fund, pension and wallet balances, and applying the right year-end rate to each year is what decides whether the catch-up stands up. Begin before the IRS or HMRC writes to you, and the Streamlined Foreign route remains open with no penalty.