Common FBAR mistakes to avoid for Global Mobility

Regarding global mobility operations, ensuring employees understand this requirement is essential. Below are some of the most common FBAR mistakes and how to avoid them.

Not realising a filing is required

An FBAR filing is required for all US persons. A US person is:

• A US citizen or business;
• A US resident (including green card holders); and 
• Certain non‑resident aliens who meet substantial presence tests during the year.

If these persons hold foreign (non‑US) financial accounts with an aggregate highest value over USD 10,000 at any point during the year, regardless of duration, they must file an FBAR.

Missing the Filing Deadline

FBARs must be filed annually by 15 April. However, if you miss this deadline, currently you automatically receive a final extension to October 15. For globally mobile persons juggling multiple tax regimes, this is easy to overlook. This date cannot be extended.

Not reporting all foreign accounts

A common misconception is that only standard bank accounts are reportable. FBAR reporting covers a wide range of foreign financial accounts, including local payroll bank accounts, investment or brokerage accounts, foreign pension or retirement accounts, mutual funds, and life insurance policies with a cash surrender value.

Neglecting to file an FBAR when no tax is due

Many taxpayers assume that if they do not owe taxes, they don’t need to file an FBAR. Even when no US tax is due, you must still submit an FBAR if your foreign accounts meet the reporting threshold at any time during the year.

Global mobility professionals should understand that the FBAR is a disclosure obligation, not a tax liability.

Forgetting to report beneficial or signature authority

Employees frequently overlook accounts where they are not the owner but can control or direct how the funds are used.

This can include company bank accounts where the employee has signature authority, accounts held in a spouse or relative’s name, and employer‑provided accounts used to manage relocation funds.

If the employee can access, manage, or direct funds, the account is usually reportable.

Not filing after closing accounts

All accounts that were open during the calendar year must be reported, even if they are now closed.

International tax reporting can be particularly challenging for globally mobile employees who must navigate both US and foreign requirements. By being aware of common FBAR pitfalls, global mobility teams can help reduce compliance risks and avoid penalties for their assignees.

If employees are uncertain about their FBAR obligations, they should seek guidance from a qualified tax professional, preferably one with global mobility expertise.

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Hannah Nelson has been practising US tax since 2015. She joined the USTAXFS London office in 2026 after previously working in the Zürich office. Prior to joining USTAXFS she worked at Ernst & Young in Germany and the US. Hannah is the European Regional Chair of GGI's Young International Taxation Practice Group (YITPG).