Offshore Account Disclosures: Ensuring FBAR and FATCA Compliance in 2025

U.S. taxpayers who hold offshore bank accounts must report these accounts to the federal government annually. While reporting thresholds apply, most taxpayers’ offshore bank accounts will easily exceed these thresholds—meaning that they must file timely and accurate reports in order to avoid penalties from the Internal Revenue Service (IRS). For those who have failed to comply in the past, coming into compliance is essential, as is making sure they meet their reporting obligations in 2025. Learn more from Washington D.C. international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group.

Offshore Bank Account Reporting Thresholds for 2025

The offshore bank account reporting thresholds remain unchanged for 2025. As has been the case for the past several years, taxpayers residing in the U.S. must report their offshore bank accounts to the IRS if:

• The total value of their offshore bank accounts (and other foreign financial assets) exceeds $50,000 on the last day of the 2024 tax year; or,
• The total value of their offshore bank accounts (and other foreign financial assets) exceeded $75,000 at any time during the 2024 tax year.

These figures double for married taxpayers in the U.S. who file jointly, and they quadruple for U.S. taxpayers living abroad.

Along with reporting their offshore bank accounts to the IRS (using IRS Form 8938), U.S. taxpayers must also report these accounts to the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN). The FinCEN reporting threshold is much lower—a $10,000 aggregate account value for all taxpayers. Thus, even if a taxpayer isn’t required to file IRS Form 8938, the taxpayer may still be required to file a Report of Foreign Bank and Financial Accounts (FBAR) with FinCEN.

Offshore Bank Account Reporting Deadline for 2025

Both IRS Form 8938 and FBARs are due on April 15, 2025 (although all taxpayers receive an automatic extension to October 1, 2025 for FBARs). Although, technically, taxpayers are supposed to attach IRS Form 8938 to their annual return even if they file early. If a taxpayer receives an extension to file their annual return, then IRS Form 8938 is due when their annual return is due.

Consequences of Failing to Timely File IRS Form 8938 or an FBAR

What if you fail to timely file IRS Form 8938 or an FBAR in 2025? Or, what if you have failed to timely file IRS Form 8938 or an FBAR in the past?

Both of these violations carry steep penalties. While these penalties are usually civil in nature (and come in the form of fines ranging from $10,000 to $100,000 or more), willful violations can lead to criminal charges in some cases. If you are concerned about facing criminal charges, working with a Washington D.C. international tax attorney to submit a voluntary disclosure—and make sure you file on time in 2025—could be your best option.

Request an Appointment with Washington D.C. International Tax Attorney Kevin E. Thorn

Do you need to know more about the U.S. offshore account disclosure requirements? If so, we invite you to get in touch. To request an appointment with Washington D.C. international tax attorney Kevin E. Thorn, Managing Partner of Thorn Law Group, please call 202-349-4033 or contact us confidentially online today.