Is the $10,000 FBAR threshold based on year-end balance or the highest balance during the year?

Llandora·Updated 2026-10-14

⚠️ Disclaimer: For general information only — not tax, financial, or legal advice. Figures may be outdated or incorrect; tax rules change frequently. Verify important decisions with the CRA/IRS or a qualified professional. You use this information at your own risk.

The short answer

The highest balance — specifically, the aggregate maximum value of all your foreign financial accounts at any time during the calendar year. Year-end balance is irrelevant to the trigger. A single large transfer passing through for one day in March can create a filing obligation for the whole year, even if every account ended December at zero.

How the test works

For each foreign account, find its highest balance at any point in the calendar year.
Convert each maximum to USD using the Treasury's December 31 exchange rate.
Add them all together.
If the total exceeds $10,000, you file FinCEN Form 114.

Three precision points people get wrong:

"Exceeds," not "equals." Exactly $10,000.00 does not trigger the filing; $10,000.01 does.
Aggregate, not per-account. Five accounts at $2,500 each = $12,500 = file.
"Foreign" is from the US perspective. For a US person, a Canadian or Mexican account is foreign; a US account is not.

A worked example

Maya, a US citizen in Mexico City, holds three accounts: a Mexican checking account (peak $6,000 in February), a Mexican savings account (peak $5,500 in November), and a Canadian TFSA (peak $4,000 in June). No single account is near $10,000 — but $6,000 + $5,500 + $4,000 = $15,500 aggregate maximum, so she files. If instead her peaks were $4,000 + $3,000 + $2,000 = $9,000, no filing is required — even if year-end balances were higher than the peaks (they can't be, by definition, but the point stands: peaks, not balances).

Frequently asked questions

What counts as a "foreign financial account"?

Bank accounts, securities accounts, and certain other financial accounts held at foreign institutions — including accounts you only have signature authority over (no ownership needed).

I closed the account in February. Still counts?

Yes — if its maximum while open contributed to an aggregate over $10,000, report it with its maximum value and mark it closed.

Sources

https://www.facebook.com/reel/2059426784667762/
IRS: FBAR reporting rules (aggregate value at any time during the calendar year) — https://www.irs.gov/newsroom/report-of-foreign-bank-and-financial-accounts-fbar-1
FinCEN Form 114 instructions — https://bsaefiling.fincen.gov/docs/FinCENFBARHelp.pdf

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Disclaimer — please read. This article is for general information and educational purposes only. It is not tax, accounting, legal, financial, or immigration advice, and reading it does not create a professional or client relationship between you and Llandora. Tax and immigration rules change frequently and differ by country, province/state, and personal circumstances; figures, thresholds, and examples in this article may be outdated, incomplete, or incorrect, and may not apply to your situation. Always verify current rules with the official sources (CRA, IRS, IRCC, USCIS) and consult a licensed professional before making any decision. Llandora makes no warranty of any kind — express or implied — about the accuracy, completeness, reliability, or timeliness of this content. To the fullest extent permitted by law, Llandora disclaims all liability for any loss, damage, cost, or expense arising from errors or omissions in this article or from any action taken or not taken in reliance on it, whether direct, indirect, incidental, or consequential. You rely on this article entirely at your own risk.