TL;DR:
- Aggregate foreign accounts over $10,000 at any moment in the year → FBAR required.
- Israeli bank, brokerage, keren hishtalmut, kupot gemel, and most pensions are reportable.
- File FinCEN Form 114 online by April 15 (automatic extension to October 15).
- No tax is due with the form — but non-filing penalties start at $10,000.
- Behind on past years? Use the Streamlined procedures, not quiet disclosure.
Step 1 — Map Every Account
List every non-US account where you have a financial interest or signature authority:
- Israeli bank accounts (checking, savings, foreign-currency).
- Israeli brokerage accounts.
- Keren hishtalmut, kupot gemel, pension funds, bituach menahelim.
- Accounts at foreign banks anywhere else in the world.
- Accounts you can sign on even if the money is not yours — an elderly parent's account, a company account you manage.
Step 2 — Test the $10,000 Aggregate Threshold
For each account find the maximum value during the calendar year (not the year-end balance), convert to USD using the Treasury's year-end exchange rate, and add them up. If the total ever exceeded $10,000, you file. Note that the maximums are taken per account on different days if needed — the test is deliberately easy to trip.
Step 3 — File FinCEN Form 114
- Go to the BSA E-Filing system (bsaefiling.fincen.gov) — no registration needed for individuals.
- Choose "File Individual FBAR".
- Enter your details exactly as on your US tax return.
- For each account: institution name, address, account number, account type, maximum value in USD.
- Submit and save the confirmation (BSA ID) — it is your only proof of filing.
The form is free, takes 20–40 minutes for a typical oleh household, and does not go through your tax preparer unless you delegate it.
The Israeli-Specific Traps
Keren hishtalmut and kupot gemel
These are reportable accounts. Worse, they are usually also PFICs — see our PFIC guide — so the FBAR is the smallest of the filings they trigger.
Pension funds
Standard practice is to report pension and provident funds where you have a financial interest. The instructions contain a narrow exception for certain employer plans, but its application to Israeli pensions is uncertain — most practitioners report.
Signature authority
Signing rights on a parent's, child's, or employer's account are independently reportable. Many olim helping elderly parents discover an FBAR obligation with zero personal money involved.
FBAR vs Form 8938
Form 8938 (FATCA) is filed with your tax return and has higher thresholds ($200,000 year-end for single filers living abroad). The FBAR is separate, goes to FinCEN, and its $10,000 threshold is far lower. Most olim who file 8938 also file the FBAR — but not vice versa. Both can apply to the same account.
If You Are Behind
Do not file late FBARs silently ("quiet disclosure") — the IRS explicitly flags the pattern. If the omission was non-willful, the Streamlined Foreign Offshore Procedures let you file three years of returns and six years of FBARs with zero penalty. Delinquent FBAR submission (without amended returns) is available when no income was unreported.
Remember: the IRS Already Knows
Under FATCA, every major Israeli bank and investment house reports US-person accounts to the IRS annually. The FBAR is not disclosure — it is confirmation. Filing late and voluntarily is almost always survivable; being discovered is not.
Not sure how this applies to you?
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