Is an Irish credit union share account reportable on the FBAR?

In our view yes. Credit union shares operate as withdrawable savings held in an account you control at a foreign institution, so we report the share or deposit account at its maximum balance during the year. A loan on which you are only the borrower is not itself reported, and a linked loan should not be netted off the share balance. If your aggregate foreign accounts exceed $10,000, the credit union account must be listed however small it is.

Do my UK accounts count towards the FBAR threshold for my Irish accounts?

Yes. The $10,000 test is the aggregate of the maximum values of all your foreign financial accounts, and UK accounts are foreign for US purposes just as Irish ones are. Most US citizens living in the UK cross the threshold through UK bank and savings accounts alone, which makes every Irish account reportable, including dormant ones and those opened in childhood that you may have forgotten about.

Does HMRC know about my Irish bank accounts?

Very likely. Irish financial institutions report accounts held by UK residents for exchange with HMRC under the international common reporting standard, and they report US persons for exchange with the IRS under FATCA. As a UK tax resident you normally owe UK income tax on Irish interest and should report it through Self Assessment, with relief available where the same income has been taxed twice.

Can I claim a US foreign tax credit for Irish DIRT?

Sometimes. The US credit is limited to compulsory foreign income tax. If you were not Irish resident and could have avoided the deduction by lodging a declaration of non-residence with the institution, or can reclaim it, the withheld amount may not qualify. We review the facts for each year before claiming it, and we usually recommend putting the correct residence declaration in place going forward.

What is the maximum non-willful penalty for a missed FBAR with several Irish accounts?

Under 31 USC 5321 the statutory non-willful maximum is $10,000, adjusted annually for inflation, and it is waived where there was reasonable cause. Following Bittner v. United States in 2023, that maximum applies per late or deficient FBAR, not per account. Four forgotten Irish accounts in one year therefore expose you to one maximum, not four, and eligible taxpayers using the Streamlined Foreign Offshore Procedures pay no FBAR penalty.

Do I need amended returns or just late FBARs for my Irish accounts?

It depends on whether income was missed. If all interest, dividends and gains from the Irish accounts were already reported on your US returns, filing late FBARs through BSA E-Filing with an explanation may be enough. If income was omitted, including PFIC income from Irish-domiciled ETFs, you need amended returns as well, and the Streamlined Foreign Offshore Procedures are normally the right route for a non-willful UK resident.

Missed FBAR: Irish Bank, Credit Union & Brokerage Accounts

Missed FBAR filings for Irish accounts are one of the most common gaps we find when a US citizen living in the UK comes to us for compliance work: an Irish current account from a Dublin job, a credit union share account opened in childhood, an Irish brokerage account holding Irish-domiciled ETFs, or a parent's deposit account you can sign on. Every one of these is generally a reportable foreign financial account, and they count together with your UK accounts towards the $10,000 aggregate threshold. If the failure was non-willful and you live in the UK, the usual fix is the Streamlined Foreign Offshore Procedures, which carry no penalty; if every dollar of income was already reported and taxed, late FBARs filed through FinCEN's BSA E-Filing System with an explanation may be enough.

What is an FBAR and why do Irish accounts trigger a Missed FBAR problem?

The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. A US person, which includes every US citizen wherever they live, must file it for any calendar year in which they had 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 year. The IRS summary of the rule is at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar. The FBAR is due on 15 April following the calendar year, with an automatic extension to 15 October that you do not need to request, and it is filed electronically with FinCEN, not with your Form 1040.

Irish accounts cause trouble for three reasons. They are often small, so the holder assumes they fall below the threshold, forgetting that the test is aggregate across every foreign account, including UK ones. Many were opened by a parent or grandparent years before the holder understood US reporting. And US citizens in the UK often think of the FBAR as a report of UK accounts. The rule has no such limitation: any account located outside the United States is foreign for FBAR purposes.

Which Irish accounts are reportable financial accounts under 31 CFR 1010.350?

The regulation that defines reportable accounts is 31 CFR 1010.350, published at https://www.law.cornell.edu/cfr/text/31/1010.350. It names three categories: bank accounts (savings, demand deposit, checking or any other account maintained with a person engaged in the business of banking), securities accounts (accounts with a person in the business of buying, selling, holding or trading stock or other securities), and other financial accounts, which include accounts with a person that accepts deposits as a financial agency, insurance or annuity policies with a cash value, and shares in a mutual fund or similar pooled fund that issues shares to the public with a regular net asset value determination and regular redemptions. The IRS adds that it does not matter whether the account produces taxable income. Applied to the Irish accounts we see most often:

Irish current and demand deposit accounts: bank accounts, reportable.
Irish savings, notice and fixed-term deposit accounts: held with a person engaged in the business of banking, reportable.
Credit union share and deposit accounts: in our view reportable; see the next section.
Irish brokerage and share dealing accounts: securities accounts, reported as one account covering everything inside.
Irish-domiciled fund holdings held directly with a fund manager or administrator: pooled fund shares with a regular net asset value, reportable in their own right.
Irish life policies with a cash or surrender value: other financial accounts, reportable.
Accounts opened for you as a child that are still open: reportable in every year the aggregate test is met, however small or dormant.

Are Irish credit union share and loan accounts reportable on the FBAR?

This is the gap in most guidance. An Irish credit union is a member-owned financial co-operative. Members hold shares, which in practice function as savings balances that can be withdrawn, and many also hold deposit accounts and loans. Because a credit union accepts savings from members and holds them in accounts that the member controls, we treat credit union share and deposit accounts as reportable foreign financial accounts, valued at the maximum share or deposit balance during the year. The label share does not take the balance outside the regulation: the question is whether you hold value in an account at a foreign institution, not what the institution calls it.

Loans are different. A loan on which you are only the borrower holds no assets of yours, so it is not the kind of account the FBAR captures. The complication is that Irish credit union loans are often linked to the share account, with part of the share balance pledged against the loan. In the returns we prepare, we do not net the loan off the share balance: the FinCEN instructions value each account by the greatest value of the currency or assets in it, and a liability on a separate loan is not a reduction in that value. Where an account itself is negative, the instructions say to enter zero, so it is still listed rather than omitted.

How do you aggregate Irish and UK accounts against the $10,000 threshold?

Add together the maximum value of every foreign account you had a financial interest in or signature authority over during the calendar year. The FinCEN filing instructions, published at https://www.fincen.gov/sites/default/files/shared/FBAR%20Line%20Item%20Filing%20Instructions.pdf, state that if the maximum value of a single account, or the aggregate of the maximum values of several accounts, exceeds $10,000, an FBAR must be filed. Once you are over the threshold, every foreign account must be reported, including an Irish account holding a few hundred euro. For most US citizens in London, UK accounts alone cross the threshold, so the forgotten Irish credit union account becomes reportable regardless of its balance. The maximum values are added even though they occurred on different days.

How do you find the maximum value and convert euro to dollars?

The FinCEN instructions define the maximum value of an account as a reasonable approximation of the greatest value of currency or non-monetary assets in the account during the calendar year. Periodic account statements may be relied on, provided they fairly reflect the maximum value. Each account is valued separately. For a brokerage account, that means the highest total value of the cash and securities in it, not the amount you paid in.

To convert euro, the instructions direct you to the Treasury exchange rate for the last day of the calendar year, now published as the Treasury Reporting Rates of Exchange; if none is available, use another verifiable rate and state the source. The year-end rate applies even if the maximum balance occurred in March, and amounts are entered in whole dollars, rounded up. Where older Irish statements are no longer online, we request them in writing early, because some institutions take weeks to respond.

How are joint accounts with Irish family members reported?

Under 31 CFR 1010.350(e)(1), each named holder of a joint account has a financial interest in it. A US citizen named on an Irish deposit account with a parent or sibling therefore reports the account, and the FinCEN instructions ask joint holders to report the full maximum value of the account, not their percentage share, together with the number of joint owners. The relative's non-US status does not change your obligation, and the fact that the money is described in the family as the parent's savings does not remove your name from the account.

There is a narrow spousal exception: a spouse need not file separately if all of their foreign accounts are held jointly with the filing spouse, the filing spouse reports them on a timely, signed FBAR, and both have completed FinCEN Form 114a. It does not apply to an account held jointly with a parent or sibling. On your Form 1040 you report only your share of the income, while the FBAR reports the full account value.

Do I report signature authority over my parent's Irish account?

Usually yes. Signature or other authority means the ability, alone or with another person, to control the disposition of money or assets in an account by direct communication with the institution. Adult children of ageing Irish parents are frequently added as authorised signatories or given a power of attorney registered with the bank so they can pay bills. If you can instruct the institution to move money, you have signature authority, and the account must be listed on your FBAR even though none of the money is yours.

Signature authority accounts count towards the $10,000 aggregate and are reported in a separate part of the FBAR. They create no taxable income for you and do not belong on Form 8938, which covers assets you own rather than accounts you can merely operate.

What about Irish accounts opened when I was a child?

Accounts opened for children are a classic source of missed filings. The FinCEN instructions are explicit that a child is generally responsible for filing their own FBAR, and that if the child cannot file, for example because of age, a parent, guardian or other legally responsible person must file it for them. A US citizen child with an Irish credit union account and a gift-funded savings account could therefore have had a filing requirement long before they knew what an FBAR was.

The years that matter now are those inside the window you are fixing. If the account is still open in your name, it is reportable in every recent year in which your aggregate exceeded $10,000. We ask every client specifically about accounts opened in their name in Ireland during childhood, and check any statements still arriving at a family address.

What happens to a dormant Irish account and does it still need reporting?

Ireland operates a statutory dormant accounts scheme under which balances on accounts that have been inactive for a long period are transferred by the institution into a state-administered dormant accounts fund. The original owner keeps the right to reclaim the money through the institution that held the account. We describe the scheme qualitatively here because the exact inactivity periods and procedures should be confirmed with the institution or the Irish authorities for your specific account.

For FBAR purposes, the account remains reportable for every year it was open and held a balance at the Irish institution; inactivity does not end the obligation. The regulation does not directly address a balance already transferred out. Our approach is to report the account for each year up to the transfer, obtain written confirmation of the transfer date and amount, and report whichever account receives any reclaimed money. Interest credited on reclaim is taxable in the US and, for a UK resident, normally in the UK too.

Do Irish accounts also go on Form 8938?

Possibly. Form 8938, Statement of Specified Foreign Financial Assets, is an IRS form filed with your Form 1040 under FATCA. It overlaps with the FBAR but is not the same: it covers specified foreign financial assets in which you have an interest, including foreign deposit and brokerage accounts and directly held foreign fund interests, and it has much higher reporting thresholds than the FBAR, which are higher again for taxpayers living abroad and vary by filing status. It does not cover accounts over which you only have signature authority. Filing one form never satisfies the other, so many UK-based clients need both. The Streamlined instructions specifically list Form 8938 among the information returns that must accompany the amended or delinquent returns when it was required. Irish institutions also identify US account holders for exchange with the IRS under FATCA, so these accounts rarely stay invisible.

Are Irish-domiciled funds and ETFs PFICs requiring Form 8621?

Usually, yes. Ireland is a major domicile for UCITS funds and exchange-traded funds sold across Europe and the UK. An Irish-domiciled fund is a non-US corporation for US tax purposes, and a pooled investment fund almost always meets the passive income or passive asset test, so it is normally a passive foreign investment company, or PFIC. A US shareholder of a PFIC generally files Form 8621 for each fund each year, subject to limited exceptions for small holdings, and faces the default excess distribution regime unless a qualifying electing fund or mark-to-market election is in place. Under the default regime, gains on sale are taxed at the highest ordinary rate for the years of the holding period, with an interest charge added.

This matters for the choice of route. A client holding Irish-domiciled ETFs almost always has unreported or misreported income, because PFIC rules were not applied, so Form 1040 and Form 8621 work is required and the FBAR cannot be fixed in isolation. The same analysis applies to Irish-domiciled ETFs held inside UK wrappers, which give no shelter from US tax.

How is Irish deposit interest taxed in the UK and the US?

Ireland applies a retention tax, known as DIRT, to deposit interest paid by Irish deposit takers, which can include credit union accounts. Non-resident account holders can generally avoid the deduction by lodging a declaration of non-residence with the institution. Many UK-resident clients never updated their Irish institution after leaving Ireland, so the tax has continued to be withheld. We describe DIRT qualitatively here; the rate and the declaration process should be confirmed with the institution or the Irish tax authority for the year in question.

In the UK, a UK tax resident normally pays UK income tax on foreign income, including interest from overseas accounts, reported on a Self Assessment return, as GOV.UK explains at https://www.gov.uk/tax-foreign-income. Relief may be available where the same income is taxed twice, and since 6 April 2025 some new UK arrivals can claim the four-year Foreign Income and Gains regime instead. In the US, the interest is taxable on Form 1040, with a foreign tax credit possible for UK or Irish tax. The trap is that the US credit is limited to compulsory foreign tax: DIRT that a declaration of non-residence would have prevented, or that can be reclaimed, may not be creditable, so we review each year before claiming it.

How do I fix a Missed FBAR for Irish accounts: Streamlined or late FBAR?

There are two realistic routes for a UK-resident US citizen whose failure was non-willful and who has not been contacted by the IRS. Note that the IRS no longer maintains a separate named procedure for late FBARs alone; the current IRS FBAR page says that if you have not been contacted and are not under investigation, you should file late FBARs as soon as possible and explain the lateness as FinCEN's instructions require.

Late FBARs only: if all income from the Irish accounts, including interest, fund distributions and PFIC income, was correctly reported and taxed, the gap is purely informational. You file the missing FBARs through the BSA E-Filing System and select a reason for late filing, or choose Other and write an explanation. Any report filed after 15 October of the following year is late.
Streamlined Foreign Offshore Procedures: if income was missed, as it almost always is with Irish ETFs, you file three years of delinquent or amended returns with required information returns such as Forms 8938 and 8621, six years of FBARs and a signed Form 14653 certification of non-willful conduct, and pay the tax and interest due.
Penalty position: eligible taxpayers who follow the foreign procedure are not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties for the covered years. The 5% miscellaneous offshore penalty belongs only to the domestic Streamlined procedures; the foreign version carries no penalty.

The Streamlined Foreign Offshore Procedures are described at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states. US citizens qualify if, in at least one of the three most recent years whose due date has passed, they had no US abode and were physically outside the United States for at least 330 full days. The FBARs are still filed through BSA E-Filing: select Other as the late filing reason and enter Streamlined Filing Compliance Procedures in the explanation box. The returns are paper filed, marked Streamlined Foreign Offshore in red at the top of the first page. Penalties already assessed are not abated, and penalties can return if an examination finds fraud or a willful FBAR violation.

What penalties apply to a non-willful Missed FBAR after Bittner?

The civil penalty statute is 31 USC 5321(a)(5), available at https://www.law.cornell.edu/uscode/text/31/5321. For a non-willful violation, the statutory maximum is $10,000, a figure the IRS adjusts annually for inflation, and no penalty applies if the violation was due to reasonable cause and the balance was properly reported. For a willful violation, the maximum is the greater of $100,000 (also inflation-adjusted) or 50% of the account balance at the time of the violation, and the reasonable cause defence does not apply.

The key development for clients with several small Irish accounts is Bittner v. United States, decided by the Supreme Court on 28 February 2023 and published at https://www.law.cornell.edu/supremecourt/text/21-1195. The government had sought $2.72 million by treating each of 272 unreported accounts across five late reports as a separate violation. The Court held that the non-willful maximum applies per report, not per account, cutting the maximum exposure to $50,000. For a client with four forgotten Irish accounts, the non-willful ceiling is one inflation-adjusted maximum per late FBAR year. The IRS stresses that penalties depend on facts and circumstances; the maximum is a ceiling, not a default.

Worked scenario: a dual US and Irish citizen in London

Illustration only. All figures are hypothetical, and the exchange rate of 1.10 US dollars to the euro is an assumption for this example, not a Treasury rate. Aoife is a dual US and Irish citizen who worked in Dublin before moving to London. She has filed US returns every year reporting her UK salary and UK bank interest, and she has filed FBARs listing only her UK accounts. A review of her Irish affairs for one recent year shows:

An Irish current account from her Dublin job, maximum balance 6,200 euro (about $6,820 at the assumed rate).
A credit union share account opened by her parents when she was eight, maximum share balance 4,800 euro (about $5,280), with a small loan linked to it.
An Irish execution-only brokerage account holding two Irish-domiciled ETFs, maximum value 38,000 euro (about $41,800).
Signature authority over her mother's Irish deposit account, maximum balance 22,000 euro (about $24,200).
Irish interest on which DIRT was withheld because she never filed a declaration of non-residence, and ETF gains and distributions that were never reported in the US.

Her UK accounts already exceeded $10,000, so each Irish account was reportable regardless of size. The credit union share account is reported at its gross maximum balance, with the loan ignored. The mother's account goes in the signature authority part of the FBAR and produces no income for Aoife. Because the ETFs are PFICs and their income was never reported, late FBARs alone will not fix the problem. She meets the 330-day test, her failure was non-willful and she has had no IRS contact, so the Streamlined Foreign Offshore Procedures fit: three amended Forms 1040 adding the Irish interest and PFIC income, Form 8621 for each ETF each year, Form 8938 where required, six corrected FBARs, Form 14653, and payment of tax and interest. No FBAR penalty applies. On the UK side, we check whether the Irish interest was declared on her Self Assessment returns and correct them with HMRC if not.

What records should I gather before filing?

Year-end and periodic statements for each Irish account for every year in the window, or the institution's written confirmation of maximum balances where statements are no longer available.
Any power of attorney or authorised signatory mandate over a parent's or relative's Irish account.
Brokerage transaction histories and fund-level details for each Irish-domiciled fund, needed for the PFIC calculations on Form 8621.
Evidence of DIRT withheld and of any declaration of non-residence filed, or not filed, with each institution.
Travel records supporting the 330-day non-residency test for at least one of the three Streamlined years.

Keep each account name, number, institution address, account type and maximum value for five years from the FBAR due date, as the IRS record-keeping rule requires, and update a single annual schedule of all foreign accounts, Irish and UK, each January. That one habit prevents the next missed FBAR.