FBAR Requirements for Americans Living in Netherlands
Our accountant mentioned FBAR casually our first year: "You'll need to file FBAR since your foreign accounts exceed $10,000."
We had never heard of it. Nobody mentioned this during our Dutch-American Friendship Treaty (DAFT) prep. Turns out, it is one of the most common things Americans abroad miss -- and the penalties are severe.
If you are a DAFT entrepreneur with a Dutch bank account, you almost certainly need to file. This is not optional, the penalties for skipping it are extreme, and the actual filing takes about 20 minutes.
What Is FBAR?
FBAR (Foreign Bank Account Report, officially FinCEN Form 114) is a disclosure to the US Treasury about your foreign financial accounts.
It's not a tax form—you're not paying taxes by filing it. You're just reporting that the accounts exist.
FBAR is part of your overall US tax obligations while living abroad.
When You Need to File
If the combined value of your foreign accounts exceeded $10,000 at any point during the year, you must file.
Key points:
- Aggregate total - add up ALL foreign accounts
- At any point - even if just for one day
- Maximum balance - use the highest balance during the year
Example: Dutch checking $8,000 max + Dutch savings $4,000 max = $12,000 aggregate. Must file, even if neither account individually exceeded $10,000.
Quick check for DAFT owners: Your DAFT business account requires a minimum EUR 4,500 deposit (roughly $4,900). You only need about $5,100 more across all other foreign accounts to hit the threshold. Most DAFT entrepreneurs cross it easily.
What Accounts to Report
Report:
- Checking and savings accounts
- Business accounts (your DAFT business account counts)
- Investment accounts
- Joint accounts (report full value)
- Accounts where you have signature authority
Don't report:
- US bank accounts
- US retirement accounts (401k, IRA, Roth IRA)
- Cryptocurrency held on US exchanges
- Real estate
What We Wish We Knew: If your partner is also a US citizen and you have joint Dutch accounts, you both need to file separate FBARs reporting the same accounts. We missed this the first year.
Step 1: Gather Account Information
For each foreign account, you need:
- Account number (IBAN for Dutch accounts)
- Name on the account
- Bank name and address
- Account type (checking, savings, business)
- Maximum balance during the year (in the account's currency)
- Currency type
Where to find maximum balances: Your Dutch bank's online portal usually shows a year-end summary (jaaroverzicht). If not, download monthly statements and find the highest balance in each account for the year.
Pro Tip: Download your jaaroverzicht in January as soon as it is available. Banks in the Netherlands typically post these by mid-January. Save them in your tax folder immediately.
Step 2: Convert to US Dollars
FBAR requires all balances in US dollars. Use the Treasury Department exchange rate for December 31 of the reporting year. Do not use your bank's rate or Google's rate.
Where to find it: Treasury Reporting Rates of Exchange at fiscaldata.treasury.gov
Example:
- Business account max balance: EUR 15,000
- Treasury rate for Dec 31: 1 EUR = $1.08 (example)
- Reported balance: $16,200
Do this for every account.
Step 3: File Online
FBAR is filed through the BSA E-Filing System, which is completely separate from the IRS e-filing system.
Website: bsaefiling.fincen.treas.gov
Process:
- Go to the BSA E-Filing System
- Select "File FBAR" (FinCEN Report 114)
- Enter your personal information (name, SSN, address)
- Enter each foreign account's details
- Review and submit
- Save the confirmation number and download the PDF
Deadline: April 15, with automatic extension to October 15 (no form required, the extension is automatic)
Cost: Free
Time required: About 20 minutes once you have all account details ready
Reality Check: We set a separate calendar reminder for FBAR because it is easy to forget. It is not part of your tax return, it is filed on a different website, and most tax software does not handle it. If you use an expat tax accountant, confirm whether they file FBAR for you or if you need to do it yourself.
Penalties
This is where FBAR gets serious.
Non-willful violations (didn't know): Up to $10,000 per violation
Willful violations (knew and didn't file): Up to $100,000 OR 50% of account balance, whichever is greater
Criminal penalties: Up to $250,000 and 5 years in prison
Penalties are per account, per year. Three years of missed filings with two accounts = six violations = potentially $60,000 in penalties.
If You're Behind
If you've missed filing in previous years, you can catch up:
Delinquent FBAR Submission Procedures:
- File all missing FBARs
- Include explanation for why you didn't file
- No penalties if you're current on tax returns and have paid all taxes owed
This is part of the Streamlined Filing Compliance Procedures for non-willful violations.
FBAR vs Form 8938
These are different forms with different thresholds, filed in different places.
| FBAR | Form 8938 | |
|---|---|---|
| Threshold | $10,000 | $200,000 (single) / $400,000 (married) |
| Filed with | BSA E-Filing (FinCEN) | IRS (with tax return) |
| Deadline | April 15 (auto-extends) | With your tax return |
| What it covers | Bank accounts only | Broader financial assets |
If your accounts are under $200,000, file FBAR only. If they exceed $200,000, file both (yes, you report the same accounts twice).
Most DAFT business owners only need FBAR.
Our Annual FBAR Checklist
Here is exactly what we do each year:
- Download jaaroverzicht from Dutch bank (January)
- Record maximum balance for each account
- Look up Treasury exchange rate for December 31
- Convert all balances to USD
- Calculate aggregate total
- File on BSA E-Filing System
- Save confirmation number and PDF
- Note filing date in tax records
Total time: about 30 minutes including gathering documents.
For a broader look at your US tax obligations, start with our complete US taxes guide. If you are unsure about handling this yourself, learn about when you need an expat tax accountant.
Digital Guide — $199
We're not tax professionals -- just Americans who file FBAR. Consult a CPA for your specific situation.