Do I need to file an FBAR for the year I moved to the UK if I only lived there for part of the year?

Yes, if the test is met. The FBAR is a calendar-year report with no part-year concept. A US citizen must file if the aggregate value of foreign financial accounts exceeded $10,000 at any time during the calendar year, as stated at https://www.fincen.gov/report-foreign-bank-and-financial-accounts. The date you arrived and your UK residence status make no difference to that test.

Does a one-off transfer for a UK house deposit trigger the FBAR?

It usually does. The threshold is tested on the maximum value of each account during the year, not the closing balance. A deposit that sits in a UK account for even a few days sets that account's maximum for the year. The home itself is not reportable, because directly held foreign property is not a financial account, but the account the money passed through is.

When is the FBAR due and is there an extension?

The FBAR is due on 15 April following the calendar year reported. FinCEN grants an automatic extension to 15 October and no request is needed, as the IRS confirms at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar. A report filed after 15 October is late and must include a reason for late filing.

My UK joint account is with my British spouse. How much do I report?

You report the entire value. FinCEN's instructions require each United States person who jointly owns an account to report the whole value of that account, not a share of it. A spouse who is not a United States person has no FBAR obligation. On Form 8938, a specified individual who owns an asset jointly with a spouse who is not a specified individual also includes the full value.

How do I file an FBAR late for my first UK year?

File it electronically through FinCEN's BSA E-Filing System and select a reason for late filing, or select other and give a short written explanation. If UK income was also omitted from your US returns, the Streamlined Foreign Offshore Procedures may be the appropriate route instead, with three years of returns and six years of FBARs. The IRS says late reports should be filed as soon as possible.

What is the penalty for one missed FBAR after the Bittner decision?

For a non-willful failure, the statutory maximum is $10,000 per violation, adjusted annually for inflation, and after Bittner v. United States the violation is counted per report, not per account. The IRS manual says no penalty should be imposed where there was reasonable cause and an accurate late report is filed. Outcomes depend on facts and circumstances, and willful failures are treated far more severely.

Missed FBAR in the Year You Moved to the UK: How to Fix It

Missed FBAR filings cluster in one place: the calendar year in which an American moved to the UK. The short answer is that the FBAR has no part-year concept. If the combined value of your non-US financial accounts exceeded $10,000 at any time in that calendar year, a report was due for the whole year, even if you lived in London for only a few months of it. A report that was not filed is corrected by filing it late through FinCEN's BSA E-Filing System with a reason for late filing, or inside a streamlined submission where tax returns also need correcting.

In the returns we prepare for executives, bankers and business owners who relocate to the UK, the arrival year is the failure mode we see most often. Sterling accounts are opened in a hurry, a relocation payment and salary arrive, a house deposit is wired across, and nobody asks the foreign account question until the second or third year.

What is an FBAR and why does the year you move count in full?

An FBAR is the Report of Foreign Bank and Financial Accounts, filed on FinCEN Form 114. It is an information report made to the Financial Crimes Enforcement Network, not a tax return, and it carries no tax of its own. FinCEN states the rule at https://www.fincen.gov/report-foreign-bank-and-financial-accounts in a single sentence: a United States person that has a financial interest in or signature authority over foreign financial accounts must file if the aggregate value of those accounts exceeds $10,000 at any time during the calendar year. The IRS repeats the same test at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar.

Two phrases decide the arrival year. The first is calendar year: the reporting period is 1 January to 31 December and there is no mechanism for reporting part of it. The second is at any time: this is not a year-end balance test and not an average. A US citizen is a United States person on every day of the year, wherever they live, so the only question is whether the accounts crossed the threshold on any single day. The date you landed and the date you became UK resident are irrelevant to the FBAR.

That is the opposite of how the UK treats the same year. The UK tax year runs from 6 April to 5 April, and GOV.UK explains at https://www.gov.uk/tax-foreign-income/residence that when you move into the UK the tax year can be split into a non-resident part and a resident part. The FBAR gives no such relief.

How is the $10,000 threshold tested when you move a house deposit across?

The threshold is tested on maximum values, not closing balances. FinCEN's line item filing instructions for Form 114 set out a two-step method. Step one is to determine the maximum value of each account during the calendar year in the currency of that account. The instructions describe this as a reasonable approximation of the greatest value in the account during the year, and allow periodic statements to be relied on provided they fairly reflect the maximum. Step two is to convert each maximum into US dollars using the Treasury exchange rate for the last day of the calendar year, or another verifiable rate with its source stated if no Treasury rate is available.

Each account is valued separately and the maximum values are then added together. This is why a property purchase so often triggers the first report. A deposit wired from a US brokerage account into a sterling account sits there for days or weeks before it goes to the conveyancing solicitor. That peak stays in the calculation even though the balance is back to a few thousand pounds by December. If the same funds pass through two of your own accounts on the way, the high point of each is counted, so the aggregate can exceed the money you actually owned.

Once the aggregate exceeds $10,000, every reportable account goes on the form, including the small ones. The IRS comparison table at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements confirms that conversion uses the calendar year-end exchange rate, not the rate on the day of the transfer.

Which accounts from the first year belong on the report?

FinCEN's instructions define a financial account broadly: securities, brokerage, savings, checking, deposit and time deposit accounts, insurance and annuity policies with a cash value, and shares in a mutual fund or similar pooled fund. An account is foreign if it is located outside the United States, so an account at a UK branch of a US institution is a foreign account. For a relocating executive, the first-year inventory usually looks like this:

A sterling current account opened to receive salary and the relocation payment, including one opened remotely before arrival.
A joint account with a spouse or partner used for household costs or to hold the house deposit.
Savings and fixed-term deposit accounts holding cash between the transfer and completion of the purchase.
Investment, share-dealing and stocks and shares ISA accounts, which are securities accounts whatever their UK tax status.
An account with a UK provider holding shares received under an employer share plan.
Workplace and personal pension arrangements with an account value.
Insurance or annuity policies with a cash value taken out in the UK.
Accounts of a UK employer or group company over which you were given signing authority.

Some things are not accounts at all. The IRS comparison table lists directly held foreign property and directly held foreign currency as not reportable on the FBAR. The London home is therefore not on the form, but the accounts the purchase money passed through are. A solicitor's client account holding the deposit is the solicitor's account, not yours.

Are accounts opened before you arrived in the UK reportable?

Yes. The obligation attaches to a United States person with a financial interest in a foreign financial account, and neither part of that test depends on where the person lives. Many employers arrange for a UK account to be opened weeks before the transfer date so that the first payments have somewhere to land. An American executive still living in New York who holds such an account already has a foreign financial account. A savings account kept from a previous secondment joins the aggregate too, and may show that earlier years were reportable.

How do joint accounts with a spouse work on a first-year FBAR?

A joint account is reported in full by each United States person who owns it. FinCEN's instructions state that, outside the spousal exception, both spouses must file separate FBARs and each must report the entire value of the jointly owned accounts. Halving the balance is a common first-year mistake and can make a reportable year look as though it falls under the threshold.

Where both spouses are United States persons, one FBAR can cover both only if three conditions are all met: every account the non-filing spouse must report is jointly owned with the filing spouse, the filing spouse reports those accounts on a timely filed FBAR, and both have signed FinCEN Form 114a, which is kept with their records rather than submitted. A spouse who also holds a sole account, such as a personal pension, never qualified for the exception. And because the exception depends on a timely filed report, we prepare a separate late FBAR for each spouse when the year was missed. Where the spouse is not a United States person, that spouse has no FBAR obligation, but the American spouse still reports the whole value of every joint account.

Do employer-arranged accounts and signing authority count?

An account that the employer or its relocation provider arranged, but which stands in your name, is simply your account: you are the owner of record. The more easily overlooked category is signature authority. A senior hire added to the mandate of a UK subsidiary's operating account has signature authority over a foreign financial account without owning a penny in it, and the IRS page confirms that this is a filing trigger in its own right. FinCEN's instructions carve out narrow exceptions for officers and employees of certain regulated financial institutions and some other specified entities, and relieve an employee who reports only signature authority from personally keeping the account records.

Are UK pension and investment accounts started in year one reportable?

Investment accounts are straightforward. A securities or brokerage account is named in the definition, and the IRS comparison table confirms that where foreign securities are held in a foreign financial account, the account is reported and its contents are not listed separately. A stocks and shares ISA or general investment account opened in the first autumn in London belongs on the report at its highest value for the year.

Pensions need more care. The retirement exceptions in FinCEN's instructions are written by reference to US law: they cover plans described in Internal Revenue Code sections 401(a), 403(a) or 403(b) and US individual retirement arrangements. A UK workplace or personal pension is not one of those listed plans. In the returns we prepare, a UK defined contribution pension with an identifiable account value is therefore included on the FBAR from the year contributions start.

When was the first-year FBAR due?

The FBAR is due on 15 April following the calendar year reported. FinCEN grants filers who miss that date an automatic extension to 15 October, and both FinCEN's instructions and the IRS page confirm that no request is needed. FinCEN's instructions treat a report as late filed when it is filed after 15 October of the year following the reporting year. Timing therefore decides whether anything was missed at all. For a move during 2025, the report for calendar year 2025 can be filed on time up to 15 October 2026. For a move during 2024, the report was due by 15 October 2025 and any filing now is a late filing that needs a reason.

Does Form 8938 apply in the year you become a UK resident?

Form 8938, the Statement of Specified Foreign Financial Assets, is a separate report attached to the income tax return, and the arrival year contains a trap we rarely see explained. The instructions at https://www.irs.gov/instructions/i8938 give two sets of thresholds. For taxpayers living in the United States, an unmarried filer or a married person filing separately must file if specified foreign financial assets exceed $50,000 on the last day of the tax year or $75,000 at any time, and joint filers at $100,000 and $150,000. For taxpayers living abroad, the figures are $200,000 and $300,000, or $400,000 and $600,000 for joint filers.

The higher set is available only to a taxpayer who meets one of two tests in the instructions: a US citizen who has been a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year, or a US citizen or resident present in a foreign country for at least 330 full days during any period of 12 consecutive months that ends in the tax year being reported. A person who arrives in June or July cannot fit 330 full days abroad into a twelve-month period ending by 31 December of that same year. Unless the bona fide residence test is met, the arrival year is measured against the lower, US-resident thresholds, and a house deposit passing through a UK account will usually clear the at-any-time figure on its own.

Three further points come from the same instructions. A specified individual who owns an asset jointly with a spouse who is not a specified individual includes the entire value. An interest in a foreign pension is a reportable asset. And the stated penalty for failing to file a complete and correct Form 8938 is $10,000, with further amounts if the failure continues after IRS notice, subject to a reasonable cause exception.

What does this look like in practice? A worked illustration

The following figures are an illustration only, not a client record, and they assume a year-end exchange rate of $1.30 to £1 purely for the arithmetic; a real report must use the Treasury rate for 31 December of the year concerned. An American executive accepts a London role starting 1 July. Her employer arranges a sterling current account in her sole name in May. A relocation payment, salary and a later bonus take that account to a peak of £95,000. In October she wires a house deposit from her US brokerage account into a joint savings account held with her British husband, where £450,000 sits for three weeks before it is paid to the solicitor. Her workplace pension stands at £9,000 by December. At 31 December the current account holds £18,000 and the joint account £6,000.

FBAR maximum values: £95,000 plus £450,000 plus £9,000 gives £554,000, or $720,200 at the assumed rate. All three accounts are listed.
Joint account: she reports the full £450,000 maximum, not half. Her husband is not a United States person and files nothing.
Year-end position: £18,000 plus £6,000 plus £9,000 gives £33,000, or $42,900. December statements alone would show modest balances.
Form 8938: filing separately from a non-US spouse and arriving mid-year, she is tested at the lower thresholds on our reading of the instructions. The year-end value of $42,900 is under $50,000, but the value at any time is far above $75,000, so Form 8938 is required.
Timing: if the move year was 2025, the FBAR can still be filed on time by 15 October 2026. If it was 2024, the report is late and is filed with a reason.

How is a Missed FBAR for the arrival year filed now?

There are two routes, and the choice depends on whether the tax returns for the same period are complete. The IRS states on its FBAR page that a person who has not been contacted by the IRS about a late FBAR and is not under civil or criminal investigation should file late FBARs as soon as possible to keep potential penalties to a minimum. The report is filed electronically at https://bsaefiling.fincen.treas.gov, where an individual does not need to register. FinCEN's instructions require a late filer to select the reason for late filing from the list on the cover page, or to select other and give a written explanation. That explanation should be short, factual and consistent with the tax returns.

A standalone late FBAR fits the executive whose US returns were otherwise complete, with all UK salary, interest and investment income reported. The Streamlined Foreign Offshore Procedures, described at https://www.irs.gov/individuals/international-taxpayers/u-s-taxpayers-residing-outside-the-united-states, fit the case where income from the UK accounts was also left off the returns. That submission consists of the most recent three years of delinquent or amended returns with all required information returns, FBARs for the most recent six years with a passed due date, full payment of tax and interest, and a signed Form 14653 certifying that the failures were non-willful. For these FBARs the IRS instructs filers to select other as the reason and enter Streamlined Filing Compliance Procedures as the explanation. A taxpayer who meets the terms of the foreign offshore procedures is not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties.

One eligibility point is specific to recent arrivals. The non-residency requirement asks a US citizen or green card holder to have had no US abode and to have been physically outside the United States for at least 330 full days in at least one of the most recent three years for which the return due date has passed. The year of a mid-year move will not satisfy that on its own. The first full calendar year in the UK normally will, but only once its return due date has passed, so we check the day counts year by year before selecting a route.

How is a single missed year assessed after Bittner?

FBAR penalties turn on whether the failure was willful. The IRS examination manual at https://www.irs.gov/irm/part4/irm_04-026-016 describes the non-willful framework. The statutory maximum for a non-willful violation is $10,000, adjusted for inflation each year. Following the Supreme Court's decision in Bittner v. United States, a non-willful failure to file is treated as one violation per report, not one per account, and the manual incorporates the IRS's interim guidance issued after that decision. An arrival-year FBAR listing eight accounts is therefore one potential non-willful violation, not eight.

The manual also records that a non-willful penalty should not be imposed where the violation was due to reasonable cause and accurate delinquent FBARs are filed to correct it, that penalties have no floor, and that an examiner may conclude a warning letter together with the corrected reports achieves compliance. The IRS states that the assertion of penalties depends on facts and circumstances.

Willfulness is a different regime with per-account exposure. The manual states that it can be shown by a knowing violation, a reckless one, or willful blindness, described as a conscious effort to avoid learning about a legal duty, and it gives the foreign accounts question on Schedule B of the return as an example.

What about the mirror image: the year you leave the UK and close accounts?

The departure year is missed for the opposite reason: by December the accounts no longer exist. The rule is identical. An account that was open on any day of the calendar year is reported for that year at its maximum value, and closing it in the summer does not remove it. It also tends to produce the largest balances of the whole UK stay, as sale proceeds from the home and a final bonus pass through UK accounts.

Two things carry on after the move back. A UK pension left in place, and any account kept open to receive a deferred bonus or a UK tax repayment, remain foreign financial accounts in every later year in which the aggregate exceeds the threshold. And the Form 8938 analysis reverses: because the 330-day test looks at any twelve-month period ending in the tax year, a person who leaves the UK part-way through the year may still meet it for the departure year, whereas the mid-year arrival could not.

What if you became a US person part-way through the year?

The same first-year problem affects people whose status changes. FinCEN's instructions define a United States resident by the residency tests in 26 U.S.C. section 7701(b), and the IRS manual confirms that these include the green card test, the substantial presence test and the first-year and last-year residency rules, adding that a green card holder living abroad can be a resident for FBAR purposes. A British executive who receives a green card mid-year becomes a United States person holding long-established UK accounts that almost always exceed the threshold.

The two reports treat that year differently. The Form 8938 instructions provide that a person who is a specified individual for only part of the year reports only that part, with the example of a person who becomes a US resident on 1 February reporting from 1 February to 31 December. The FBAR instructions contain no comparable part-year period: they ask for the maximum value during the calendar year being reported. Establishing the residency start date under section 7701(b) is therefore the first step, and the one most often skipped.

What records should you gather before filing the late report?

FinCEN's record keeping rule requires records to be kept for five years from 15 April of the year following the calendar year reported, or from the date filed if later. The same items are what we need to prepare a late report accurately:

The name in which each account is held, the account number, and the name and address of the institution.
The type of account: bank, securities or other.
Statements for the whole calendar year, including months before the move date, so the true maximum can be identified.
Details of every joint owner, and any signed Form 114a.
Completion statements and transfer confirmations for the property purchase, to trace which accounts the deposit passed through.
Pension and investment valuations for the year.
The US returns for the same years, including the Schedule B foreign accounts answer and any Form 8938, so the late report and the returns agree.

The first FBAR is the one most often missed, but it is also among the most straightforward to correct when the report is filed before anyone asks for it.