Do I have to report my KiwiSaver account on the FBAR?

In the returns we prepare, yes. KiwiSaver is a retirement savings balance held with a New Zealand provider, outside the United States, so it is treated as a foreign financial account. It is listed at its maximum value for the year once all your foreign accounts together exceed $10,000 at any time. The wider US income tax classification of KiwiSaver is a separate technical question beyond FBAR reporting.

Is a closed New Zealand bank account still reportable on a late FBAR?

Yes. The FBAR reports accounts that existed during the calendar year, so an account is reportable for every year in which it was open and your aggregate foreign balances exceeded $10,000, including the year it was closed. Use its highest balance while open. Request historic statements early, because closed-account records are often slower to obtain.

What exchange rate do I use to convert New Zealand dollars for the FBAR?

Find the maximum value of each account in New Zealand dollars from periodic statements, then convert it once using the end-of-calendar-year exchange rate. The IRS FBAR page points to Treasury's Reporting Rates of Exchange dataset for current and historical rates. Form 8938 also uses a year-end rate, but values are determined at fair market value under its own instructions.

Is there a penalty under the Streamlined Foreign Offshore Procedures?

No. The IRS states that taxpayers who meet the requirements and follow the instructions are not subject to failure-to-file, failure-to-pay, accuracy-related, information return or FBAR penalties. You pay any tax due plus statutory interest. The 5% miscellaneous offshore penalty applies only to the Streamlined Domestic Offshore Procedures for US residents.

Do I need to tell HMRC about interest on my New Zealand accounts?

Usually, yes. GOV.UK says UK residents with foreign income generally need to file a Self Assessment return, and New Zealand interest is foreign income. If you do not normally file, tell HMRC by 5 October after the tax year concerned. Where New Zealand taxed the interest, include it to claim Foreign Tax Credit Relief if eligible, and check whether Foreign Income and Gains relief applies to you.

My husband is not a US citizen. Who reports our joint New Zealand account?

You do. The spousal filing exception only works where both spouses have FBAR obligations and one files for both using FinCEN Form 114a. A non-US spouse has no FBAR to file, so the US spouse lists every joint New Zealand account on their own FBAR. His sole-name accounts are not yours to report unless you hold signature authority or a financial interest.

Missed FBAR: New Zealand Accounts and KiwiSaver

A Missed FBAR on New Zealand accounts is one of the most common gaps we find when a US citizen relocates from Auckland or Wellington to London: the everyday account, the term deposits, the KiwiSaver balance and the managed fund holdings were never reported to FinCEN. The direct answer is that New Zealand bank accounts and term deposits are foreign financial accounts, and if the combined value of all your foreign accounts went above $10,000 at any time in a calendar year, each one belongs on that year's FBAR. KiwiSaver is, in the returns we prepare, treated as a reportable foreign account as well. The fix is usually the Streamlined Foreign Offshore Procedures, which carry no penalty for non-willful filers, or a late FBAR filed through FinCEN's BSA E-Filing System with a reason for late filing.

What is a Missed FBAR and why do New Zealand accounts trigger it?

The FBAR is FinCEN Form 114, the Report of Foreign Bank and Financial Accounts. A missed FBAR is simply a year in which you were required to file that report and did not. The IRS summary at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar sets out the test: a US person with a financial interest in, or signature or other authority over, at least one financial account outside the United States must file if the aggregate value of those foreign accounts exceeded $10,000 at any time during the calendar year. FinCEN states the same threshold at https://www.fincen.gov/report-foreign-bank-and-financial-accounts.

Three features of that rule catch New Zealand movers out. First, the threshold is aggregate, not per account, so a modest everyday account plus a term deposit plus a KiwiSaver balance can easily cross it together even if none of them does alone. Second, the test is any time during the year, so a single week in which a house deposit or a bonus sat in an account is enough. Third, the IRS is explicit that whether the account produced taxable income does not matter. A non-interest-bearing account still counts.

US citizenship is the trigger, not residence. A US citizen who lived in New Zealand for decades and paid New Zealand tax on everything was still a US person throughout, and the same is true now in the UK: UK accounts, any New Zealand accounts you kept and anything else held outside the United States all go into the aggregate.

Which New Zealand accounts are reportable on the FBAR?

In the returns we prepare for clients who have relocated from New Zealand, the reportable list usually looks like this. Each item is a financial account held at an institution outside the United States, and each must be listed separately with its own maximum value once the aggregate test is met.

Everyday transaction accounts and on-call savings accounts at New Zealand banks, including accounts you rarely use and accounts held only to receive New Zealand rent or dividends.
Term deposits, including short fixed-term deposits that matured during the year. A term deposit that rolled over is usually still the same reportable account, but check whether the institution issued a new account number.
KiwiSaver accounts. Inland Revenue describes KiwiSaver as a voluntary savings scheme to help members save for retirement, funded through member contributions, employer contributions and Government contributions.
Managed fund and unit-style investment accounts held directly with a New Zealand fund manager, and brokerage or custody accounts holding New Zealand or global shares.
Joint accounts with a spouse or partner, including a spouse who is not a US person.
Accounts over which you have signature authority but no ownership, such as a business account for a New Zealand company you still help run, or an account of an elderly parent where you hold a mandate.
Accounts that were closed during the year, which remain reportable for every year in which they were open and the aggregate test was met.

Physical cash, directly held New Zealand property and shares held in your own name on a share register rather than through a financial institution are not financial accounts for FBAR purposes, though they may matter for Form 8938 and for income reporting.

Is KiwiSaver reportable on the FBAR?

KiwiSaver is the item clients most often assume is exempt. The reasoning we hear is that it is a retirement scheme, it is locked away, and US retirement accounts have special FBAR treatment. That last point is the source of the confusion. The IRS FBAR page does list certain IRAs and retirement plans among excluded accounts, but those exceptions are aimed at US arrangements, not at foreign schemes. A KiwiSaver balance is held by a New Zealand provider, in New Zealand dollars, outside the United States.

Inland Revenue's own description at https://www.ird.govt.nz/kiwisaver is of a voluntary retirement savings scheme to which members contribute from pay or directly to their provider, with employer contributions and Government contributions on top. From a FinCEN perspective, that is a balance held for you with a foreign financial institution. In our practice we include each KiwiSaver account on the FBAR at its maximum value for the year, and we see this as the defensible default position.

It is important to separate two questions. Reporting KiwiSaver on the FBAR is a disclosure exercise: you are telling FinCEN the account exists and roughly how much it held. The wider US income tax classification of KiwiSaver, including how contributions and growth are taxed on a US return, is a separate technical question beyond FBAR reporting. It depends on the scheme and the funds chosen inside it, and it needs to be worked through on the Form 1040 side rather than assumed away. This guide stays with the FBAR and the information returns that sit alongside it.

How do you value New Zealand dollar accounts for the FBAR?

The FBAR asks for the maximum value of each account during the calendar year, not the year-end balance and not the average. The IRS record-keeping list at https://www.irs.gov/businesses/small-businesses-self-employed/report-of-foreign-bank-and-financial-accounts-fbar includes the maximum value during the year as a required item for every reportable account, alongside the name on the account, the account number, the institution's name and address, and the account type.

The conversion method is set out on the IRS comparison page at https://www.irs.gov/businesses/comparison-of-form-8938-and-fbar-requirements. For the FBAR you use periodic account statements to find the maximum value in the account's own currency, here New Zealand dollars, and then convert that figure to US dollars using the end-of-calendar-year exchange rate. The IRS FBAR page links to Treasury's Reporting Rates of Exchange dataset for current and historical rates, and that is the source we use. Two practical consequences follow.

You do not convert each month's balance at that month's rate. You find the highest New Zealand dollar balance and convert it once, at the year-end Treasury rate for that calendar year.
The aggregate test is run on the converted figures. Accounts that look small in New Zealand dollars can cross $10,000 in total once a strong year-end rate is applied, and the reverse can also happen.
For KiwiSaver and managed funds, the maximum value is the highest unit value shown on statements during the year. Where only annual or quarterly statements exist, a reasonable, documented approximation from the statements is what we work from.
Keep the statements. The IRS requires FBAR records to be retained for five years from the FBAR due date.

How does Form 8938 overlap with the FBAR for New Zealand assets?

Form 8938, the Statement of Specified Foreign Financial Assets, is filed with your US income tax return under FATCA. It is a separate obligation from the FBAR, and filing one does not satisfy the other. The thresholds are also much higher for people living abroad. According to the IRS comparison page, an unmarried US taxpayer living outside the United States files Form 8938 if specified foreign financial assets total more than $200,000 on the last day of the tax year or more than $300,000 at any time during the year. For married couples filing jointly, those figures are $400,000 and $600,000.

Many of the clients we see from New Zealand clear those thresholds once KiwiSaver, term deposits and managed funds are added to UK investment accounts. Form 8938 converts at the end-of-taxable-year rate at fair market value, it can reach non-account assets such as directly held foreign shares, and foreign mutual funds are reportable on both forms. The penalty regime is also separate: the IRS lists up to $10,000 for failure to disclose on Form 8938, with further amounts after IRS notice.

Where a missed FBAR exists, a missed Form 8938 usually exists too, because both were skipped for the same reason. Any clean-up therefore has to rebuild both, consistently, from the same set of statements.

Are New Zealand managed funds a PFIC problem?

Often, yes. A passive foreign investment company, or PFIC, is a foreign corporation that meets either of two tests set out in the Form 8621 instructions at https://www.irs.gov/instructions/i8621: the income test, where 75% or more of its gross income for the year is passive income, or the asset test, where at least 50% of its assets produce, or are held to produce, passive income. A pooled investment fund organised outside the United States that is treated as a corporation for US tax purposes will usually meet one or both tests almost by design, because its income is dividends, interest and gains.

That has three consequences for a US citizen holding New Zealand managed funds directly. First, a separate Form 8621 is generally required for each PFIC held, attached to the income tax return. Second, without an election, the fund is taxed under the default section 1291 regime, a punitive default regime for excess distributions and gains on disposal. Third, the two elections that soften this, the qualified electing fund election and the mark-to-market election, generally have to be made on a timely filed return, which is exactly what a person with a missed FBAR usually does not have.

There is a limited reporting exception in the Form 8621 instructions: a shareholder of a section 1291 fund need not complete Part I if the aggregate value of PFIC stock is $25,000 or less at the end of the tax year, or $50,000 for a joint return, and there is no excess distribution or disposition gain. For most of the clients we see, the New Zealand fund holdings are well above that. The PFIC analysis is an income tax question rather than an FBAR one, but it changes the cost of the clean-up, so it has to be scoped at the start.

How do you fix a Missed FBAR with the Streamlined Foreign Offshore Procedures?

For most US citizens who have lived outside the United States throughout, the Streamlined Foreign Offshore Procedures are the right route. The IRS page at https://www.irs.gov/individuals/international-taxpayers/us-taxpayers-residing-outside-the-united-states sets the conditions. A US citizen must 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, and must not have had a US abode. If you file jointly, both spouses must meet the non-residency requirement. The failure must also be non-willful, which the IRS defines as conduct due to negligence, inadvertence or mistake.

A submission under the foreign procedures involves the following steps.

Prepare and file the three most recent years of US income tax returns for which the due date has passed, delinquent or amended as needed, including Form 8938, Forms 8621 for New Zealand funds and any other required information returns.
File the FBARs for the most recent six years for which the FBAR due date has passed, electronically through FinCEN's BSA E-Filing System, selecting Other as the reason for late filing and entering Streamlined Filing Compliance Procedures in the explanation box.
Complete and sign Form 14653, the non-willful certification for US persons residing outside the United States, giving a specific factual account of why the accounts were not reported.
Write Streamlined Foreign Offshore in red at the top of the first page of each return and information return, and mail the paper package to the address on the IRS page.
Pay all tax due plus statutory interest. If you have no Social Security number and are not eligible for one, an ITIN application goes in with the returns.

The headline benefit is that there is no penalty. The IRS page states that taxpayers who comply with the instructions will not be subject to failure-to-file and failure-to-pay penalties, accuracy-related penalties, information return penalties or FBAR penalties. The 5% miscellaneous offshore penalty sometimes mentioned online belongs to the Streamlined Domestic Offshore Procedures for US residents, not the foreign procedures. Penalties can still apply if an examination later finds fraud or a willful FBAR violation, and penalties already assessed are not abated, which is why the narrative on Form 14653 has to be accurate and complete.

When is a late FBAR with a reason enough on its own?

Some clients have no income tax problem at all. Every return was filed, all New Zealand interest was reported, foreign tax credits covered the US liability, and the only failure was the FBAR itself. For that profile, a late FBAR filed through FinCEN's BSA E-Filing System with an explanation of the delay can be the proportionate fix. The IRS FBAR page says that if you have not been contacted by the IRS about a late FBAR and are not under civil or criminal investigation, you should file as soon as possible to minimise potential penalties, and follow FinCEN's late-filing instructions to explain why the report is late.

The IRS previously published a named procedure for delinquent FBAR submissions. That page was withdrawn around 1 July 2026, and we do not present it as a live route. In the current environment, a late FBAR stands on its own facts and its own explanation. If there is any unreported income, any missing Form 8938 or any unfiled Form 8621, the late-FBAR-only approach leaves those failures open, and the Streamlined route is usually the better fit.

What about closed New Zealand accounts and accounts with a non-US spouse?

Two gaps we see repeatedly are rarely covered well.

Closed accounts. Clients often close New Zealand accounts before or shortly after moving to the UK and assume that ends the problem. It does not. The FBAR is an annual report of accounts that existed during the calendar year, so an account closed in March is still reportable for that year and for every earlier year in the filing window, at its maximum value while it was open. The practical challenge is records: once an account is closed, statements can be harder to obtain, so we ask clients to request historic statements early in the engagement.

Accounts with a non-US spouse. Many movers from New Zealand are married to a New Zealand or UK national who is not a US person. The spousal exception on the IRS FBAR page allows one spouse to file for both only where the accounts are jointly owned, the non-filing spouse has signed FinCEN Form 114a, and the filing spouse reports the joint accounts on a timely, signed FBAR. A non-US spouse has no FBAR obligation and does not file one, so that exception is not available. The US spouse lists every joint New Zealand account on their own FBAR. The non-US spouse's sole-name accounts are not reportable by the US spouse unless the US spouse has a financial interest in them or signature authority over them, which is worth checking where there are household accounts with shared mandates.

Does a UK resident also have to report New Zealand interest to HMRC?

Yes, as a general rule, and this is the half of the problem US-focused guides tend to skip. GOV.UK says at https://www.gov.uk/tax-foreign-income/paying-tax that you usually need to fill in a Self Assessment tax return if you are a UK resident with foreign income or capital gains. Interest on a New Zealand everyday account or term deposit is foreign income. The narrow exception on that page applies only where your only foreign income is dividends within the dividend allowance and you have nothing else to report, which will not cover New Zealand interest.

If you do not usually send a UK return, GOV.UK says you need to tell HMRC by 5 October following the tax year in which you had the income. Where New Zealand has already taxed the interest, GOV.UK directs you to include that income on the return to claim Foreign Tax Credit Relief if you are eligible. The same page notes that different rules may apply if you are eligible for Foreign Income and Gains relief, and that before 6 April 2025 different rules may have applied where your permanent home was abroad. Recent arrivals from New Zealand should check whether that relief applies to them before assuming New Zealand interest is fully taxable in the UK, and anyone who missed earlier UK years should correct them alongside the US clean-up so the two sets of figures agree.

The UK treatment of KiwiSaver and of New Zealand managed funds has its own rules and is dealt with on the UK return. The point here is coordination: what you disclose to the IRS and FinCEN should reconcile with what you report to HMRC.

Worked example: a Missed FBAR across New Zealand and the UK

Illustration only. All figures are invented for this example, and the exchange rate is an assumption, not a published Treasury rate. Assume a single US citizen moved from New Zealand to London several years ago. She has filed US returns each year reporting her UK salary, but has never filed an FBAR, Form 8938 or Form 8621. During each year in the filing window she held the following New Zealand assets, with maximum values taken from statements.

Everyday account: maximum NZD 18,000 during the year.
Term deposit: maximum NZD 120,000, matured and reinvested mid-year.
KiwiSaver: maximum NZD 210,000.
Directly held New Zealand managed fund: maximum NZD 95,000.
Joint savings account with her non-US husband, closed in the third year: maximum NZD 40,000 while open.

Assume, for illustration, a year-end rate of 0.60 US dollars per New Zealand dollar. The everyday account converts to $10,800, already above the $10,000 aggregate threshold on its own. The term deposit is $72,000, KiwiSaver $126,000, the managed fund $57,000 and the joint account $24,000. Every account goes on each year's FBAR, and the joint account appears on her FBAR for each year up to and including the year of closure. Her UK accounts are added to the same FBARs.

On Form 8938, the New Zealand figures alone, at the end-of-year rate and before her UK investments, may well exceed the $200,000 year-end or $300,000 any-time thresholds for a single filer living abroad, so Form 8938 is needed. The managed fund is above the $25,000 Form 8621 exception and is likely to be a PFIC, so Form 8621 is needed for each year in the three-year return window, with the section 1291 consequences quantified. Her New Zealand interest has not been reported on her US returns, so amended returns are needed. She meets the 330-day test and her failure was non-willful, so she files under the Streamlined Foreign Offshore Procedures: three years of amended returns with Forms 8938 and 8621, six years of FBARs through BSA E-Filing, Form 14653, and payment of any tax and interest, with no penalty. On the UK side, she checks that each year's New Zealand interest appears on her Self Assessment returns, with Foreign Tax Credit Relief for New Zealand tax where she is eligible.

What records should you gather before fixing a Missed FBAR?

The quality of a clean-up depends on the statements behind it. We ask New Zealand movers for an inventory of every account across the six FBAR years, statements showing each year's highest balance, KiwiSaver and managed fund statements, closure dates, any signed Form 114a, and the matching US and UK returns. Building the FBAR, Form 8938, Form 8621 and UK figures from one data set is what makes a Streamlined certification credible.

A Missed FBAR on New Zealand accounts is common, fixable and, for non-willful filers living abroad, usually resolved without penalty. The real work sits in what travels with it: Form 8938, PFIC reporting on New Zealand funds, and aligning the US and UK pictures. We prepare the full package so that each filing supports the others.