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Federal guide · checked 13 October 2026

FBAR for a foreign-owned US LLC

Your US LLC counts as a "US person" for FBAR, even when every owner lives abroad. If the company has accounts outside the US that together top $10,000 at any point in the year, it must file an FBAR.

The rule

  • Who: any US entity, including a single-member LLC owned by a non-US person, with a financial interest in or signing authority over financial accounts outside the US.
  • Threshold: the highest balances of all those accounts, added together, went over $10,000 at any time during the calendar year. Even for one day.
  • Form: FinCEN Form 114, filed online through the BSA E-Filing System. It's free and isn't part of your tax return.
  • Due: 15 April, with an automatic extension to 15 October. No form is needed for the extension.

Which accounts count

AccountCounts for FBAR?
US bank or fintech account (Mercury, Relay, a US bank)No, it's in the US
Bank account in your home country in the LLC's nameYes
Non-US currency balances held by a fintech's non-US entityOften yes; check which country's entity holds the money
Foreign payment accounts that hold balances (some payout wallets)Possibly; FinCEN treats some as financial accounts. Ask a preparer.
Your personal account abroadNot for the LLC. You personally file only if you are a US person.

Penalties

Missing an FBAR without meaning to can still cost a civil penalty of over $10,000 per late report (the amount is adjusted for inflation each year; the Supreme Court ruled in Bittner (2023) that non-willful penalties apply per report, not per account). Willful violations cost far more. If you've missed years, FinCEN and the IRS have a delinquent FBAR procedure: file the late reports with a short explanation.

Also owed by a foreign-owned LLC

  • Form 5472 with a pro forma 1120 by 15 April. Guide.
  • Your state's annual report, e.g. Wyoming.

Check everything my company owes

Sources: 31 CFR 1010.350 (who must report, the $10,000 test, US entities as US persons); FinCEN BSA E-Filing (Form 114 and the automatic October extension); Bittner v. United States, 598 U.S. 85 (2023).